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Measuring the Value of Your Compliance Program. Sarah N. Flanagan Senior Compliance Counsel Intel Corporation March 13, 2014. Federal Sentencing Guidelines.
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Measuring the Value of Your Compliance Program Sarah N. Flanagan Senior Compliance Counsel Intel Corporation March 13, 2014
Federal Sentencing Guidelines • A company convicted of criminal misconduct may receive reduced punishment if it had an effective compliance and ethics program in place at the time of the offense • An effective compliance and ethics program can also help enable a company to: • Avoid prosecution • Successfully advocate for a non-prosecution or deferred prosecution agreement (and mitigate fines) • Reduce risk of civil liability
Measuring the Value of a Compliance Program is Challenging • How do you prove a negative? • If you have no excursions, is that a good thing or a bad thing?