Corporations were given a significant incentive to revisit their compliance programs this week, as the U.S. Sentencing Commission (the Commission) made public a proposed policy change that would offer substantial benefits to corporate defendants who could demonstrate that they have an adequately designed and deployed program for combating white collar crime. The Commission is in the midst of its current session, during which it has chosen to address how corporations are handled in criminal cases. This week’s announcement was a notable sign that the Commission intends to take concrete steps to create incentives for enhancement of corporate compliance programs — an area on which the Commission and U.S. Department of Justice (DOJ) have placed increasing emphasis over the years.

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