Corporate Compliance and Ethics Programs: A Detailed Look at U.S. Sentencing Guidelines

Workplace fraud through asset misappropriation, corruption and deceptive financial reporting continues to plague virtually all types of organizations. While, many companies have combated fraud to some degree, the effort often falls short for a variety of reasons. A comprehensive compliance and ethics program will help mitigate the risks of adverse legal actions, including those associated with rules and regulations of the Securities and Exchange Commission (SEC) and the Foreign Corrupt Practices Act (FCPA). This training session explores common reasons for failure; and more importantly, discuss solutions through seven minimum requirements for encouraging ethical conduct and demonstrating a commitment to compliance with the law as published by federal guidelines.

These requirements include:

• Establishing standards and procedures, such as a code of conduct and appropriate policies to prevent and detect criminal conduct
• Governing authority involvement
• Reasonable efforts to avoid relying on the wrong employees for sensitive positions
• Steps to communicate periodically and in a practical manner the compliance and ethics program
• Reasonable steps to help ensure that the compliance and ethics program is followed
• Promoting and enforcing the compliance and ethics program consistently
• Actions to respond to the criminal conduct and to prevent further similar criminal conduct

Learning objectives:

• Understand recent and proposed changes with federal sentencing guidelines
• Become aware of recent federal enforcement trends
• Learn about the seven minimum requirements for encouraging ethical conduct and demonstrating a commitment to federal compliance
• Explore a holistic and sound corporate compliance and ethics program
• Identify warning signs to workplace fraud and non-compliance
• Explore the reasons why company efforts to combat fraud often falls short
• Learn anti-fraud controls and the impact of a healthy control environment
• Explore examples of how to strengthen the control environment through a holistic compliance and ethics program