Abstract
In November 2004, the United States Sentencing Commission amended the federal organizational Sentencing Guidelines to clarify and expand the criteria for an effective ethics and compliance program. This development spurred a new push within companies to re-evaluate and update their compliance and ethics programs. To take stock of how companies are responding to the amended guidelines, the South Texas College of Law Corporate Compliance Center conducted a best practices survey on four key compliance topics:
The Board's Role in the Compliance and Ethics Program
Structuring the Compliance Function
Evaluating the Compliance and Ethics Program
Compliance and Ethics Training
This article analyzes selected results from the Survey.