Washington University Law Quarterly
This Article discusses the advantages and disadvantages of implementing an effective compliance program. It then discusses the specific elements that the Guidelines require for a sentencing court to find a compliance program effective and thus entitled to credit as a mitigating factor in the sentencing process. Finally, the Article sets forth a basic framework for establishing a compliance program that will satisfy the Guidelines' requirements.
Dan K. Webb and Steven F. Molo,
Some Practical Considerations in Developing Effective Compliance Programs: A Framework for Meeting the Requirements of the Sentencing Guidelines,
71 Wash. U. L. Q. 375
Available at: http://openscholarship.wustl.edu/law_lawreview/vol71/iss2/7