“Did you ever expect a corporation to have a conscience, when it has no soul to be damned, and no body to be kicked?” — Edward Thurlow, 18th century British Lord Chancellor1
We are approaching the tenth anniversary of what, at the time, appeared to be a watershed moment in the evolution of corporate compliance programs: the 2004 amendment of the Federal Sentencing Guidelines for Organizations (Guidelines) which, for the first time made explicit the U.S. Sentencing Commission’s fundamental proposition that “organizations must promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.”
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