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Many times I am asked: What does the government expect in a compliance program?
I hesitate to respond that you should look at the Federal Sentencing Guidelines, as that is an uncomfortable way to start any friendly conversation. The Guidelines do, of course, provide the foundation. But there is another significant resource from which you can learn what the government is thinking and it is the numerous deferred or non-prosecution agreements that have been entered into and which include the compliance requirements the government expects the company to meet. An excellent collection of these agreements can be found at the University of Virginia Law School website.
If you have any problems, let me know, as I also have a good collection.
Bart M. Schwartz is the chairman of Guidepost Solutions LLC, a global leader in investigations, due diligence, security and technology consulting, immigration and cross-border consulting, and monitoring and compliance solutions.