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In addition to the previously published seven elements of an effective compliance program, the 2004 review of Chapter 8 of the Federal Sentencing Guidelines emphasized the necessity of an ethical culture. The term “ethical culture” received widespread press over the years, but has been more recently replaced with the term “culture of compliance.” Without entering the debate about the difference between ethics and compliance, let’s explore one method of how to establish and sustain such a culture after the compliance policies, accountability, and communication are in place, and the “tone at the top” (meaning the CEO) is without reproach.

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