What is the “bare minimum” an organization needs to have an effective compliance program? Is that even the right question? Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines, and that is: what must we do? In Part I of a two-part series, Eric talks about how the Guideline standards are really the floor for expectations. We spend some time also talking about the guidance in the Guidelines, in particular the importance of the Application Notes of the Guidelines that are often overlooked.
Eric also discusses the treatment of different sized organizations regarding compliance commitment and resources. Eric also mentions that valuable data and information is available at the US Sentencing Commission’s website. We discuss the importance of compliance professionals being directly familiar with the Sentencing Guidelines.
Finally, Eric walks through the first four of the “Seven Hallmarks”. We discuss the fact that what the Hallmarks aren’t even necessarily agreed on all the time (see Joe Murphy’s discussion here). Eric talks about standards, individuals with a compliance program responsibilities, due diligence to ensure no bad actors with program authority and communicating the program.