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Here are the feds' 7 tips for corporate compliance plan

April 1, 1998

Here are the feds' 7 tips for corporate compliance plan

The seven elements as listed in the Federal Sentencing Guidelines are as follows:

1. assigning a high-level person or group to oversee the plan;

2. establishing rules and procedures that will reasonably reduce the prospect of illegal or wrongful acts;

3. instituting policies that prevent assignment of substantial discretionary authority to people that the company knew or should have known had the propensity to commit illegal acts;

4. ensuring effective communication of program rules and procedures to all employees;

5. taking reasonable steps to monitor and audit operations to detect criminal conduct including establishing a system for anonymous reporting of suspected illegal conduct;

6. using disciplinary procedures, employee annual review, and employee counseling programs to instruct employees on instances creating the duty to report suspected criminal conduct;

7. establishing appropriate responses to offenses and amending ineffective compliance plan procedures to prevent offenses when necessary.