U.S. Sentencing Guidelines


National Security and FCPA Investigations

The FCPA is one of many tools the DOJ and the SEC put to use in facilitating national security in the U.S. And while they are some of the largest players in protecting the nation's interests, compliance professionals working for global corporations also play a critical role in identifying vulnerabilities and doing serious due diligence to minimize risks.

rewarding employees ethical behavior

The Story of Ajax: Fairness in Rewarding Employee Behaviors

How does your company deal with the question of fairness in its corporate compliance program? I thought about that question while reading an article in The New York Times (NYT) entitled “That Eternal Question of Fairness” by Nancy Koehn. In her article, Koehn discusses Paul Woodruff's book, The Ajax Dilemma: Justice, Fairness and Rewards, which considers how a company ...


The Compliance Interview – 6 Helpful Questions

As an independent corporate monitor, I am, among other things, obligated to assess the effectiveness of the corporate compliance programs of the organizations I monitor. Interviews of company personnel have proven to be one of the most reliable and effective tools in making this assessment. While many of the people interviewed are chosen randomly from […]

DOJ Seeks Sentencing Enhancement

Over the summer, Jonathan Wroblewski of the DOJ submitted a report commenting on the operation of the sentencing guidelines and suggesting changes in the guidelines that appear to be warranted.