This time, in anticipation for a Sentencing Guideline presentation next month at the SCCE’s CEI in Washington DC, we have another belated edition of Sentencing Commission Confidential. Eric talks about a commonly overlooked or misunderstood part of Chapter Eight of the guidelines that sets out responsibilities for reporting to the Board (or governing authority) of an organization. If you or your organization still struggles with what that conduit to the Board should look like, take a listen. Eric references parts of Chapter Eight of the guidelines which can be found here.
This time Eric discusses compliance program assessments – or risk assessments – or program benchmarking – or whatever you want to call the periodic review of your program that the Sentencing Guidelines, USDOJ guidance and best practices call for. Eric discusses three key pieces of the puzzle you might want to consider whether you are undertaking the assessment internally or evaluating outside assistance.
Eric mentions Chapter Eight of the Sentencing Guidelines in the podcast, the text of which can be found here.
One of the questions raised by the recent updated USDOJ guidance is the question of “expertise” at or on the board of directors. Eric takes some time this week to discuss the guidance and the practical considerations about expertise in the boardroom.
If you are interested in the intersection of compliance and the board of directors, please join Eric for a webinar on the topic July 31st at 1PM ET. “What Should Your Board Know About Compliance and Ethics?” click here for more information.
One of the areas many compliance teams still struggle with is getting a consistent, effective informal communication plan off the ground. Eric has a few ideas that might help focus informal communication efforts at your organization. Eric talks about being realistic regarding time and resources and thinking strategically about what might reach your audience.
After a dozen episodes detailing the new guidance, what are some parting thoughts? Eric talks a little about the memo’s impact and potential impact as well as highlighting some of the more important concepts the Department has chosen to highlight.