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A new survey, fielded jointly by the SCCE, Ethics Resource Center and the Ethics and Compliance Officer Association, reveals the depth of the demand for more data from DOJ on the consideration given ethics and compliance programs in enforcement decisions.

“Compliance and ethics professionals needs this information to demonstrate to their leadership that the United States Sentencing Guidelines Chapter 8 actually means something,” said Roy Snell, Chief Executive Officer of the Society of Corporate Compliance and Ethics. Chapter 8 of the guidelines governs the punishment of an organization when it is found guilty of criminal conduct. However, if the organization can demonstrate it had an effective compliance program in place, it can substantially mitigate the impending fine.

  • Additional data ethics and compliance professionals would like the DOJ to make public include:
  • Descriptions—without identifying information—of individual cases in which ethics and compliance programs were a mitigating factor in enforcement decisions.
  • Information about what specific aspects of an Ethics and Compliance program factored into enforcement decisions.
  • Information about the benefits of an effective Ethics and Compliance program, such as helping avert a decision to prosecute or avoidance of other sanctions such as appointment of a monitor.

Download Survey