The first corporate ethics offices were created in 1985 to provide employees with training about company standards of conduct and their applicability to particular job responsibilities. The offices were also designed to be a confidential means to seek advice about difficult business situations, as well as to report misconduct without fear of reprisal. The U.S. Sentencing Commission looked specifically to such programs when in 1991 it articulated the mitigation factors to be considered when sentencing organizations. The Commission’s focus on deterrence and detection of crime caused many companies to transform existing ethics programs into ethics and compliance offices. In 2004, the Commission issued revised guidelines in an effort to shift the corporate focus back to ethics and to management’s responsibility to create an ethical culture in order to achieve compliance.
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USDOJ Steps Up FCPA Enforcement
1 Dec 2010
Detailing a “new era” of Foreign Corrupt Practices Act (FCPA) enforcement, Lanny Breuer Assistant Attorney General of the Criminal Division in the US Department of Justice said that those worried about more aggressive anti-bribery enforcement “are right to be more concerned.” In prepared remarks, Breuer said, “Our FCPA enforcement is stronger than it’s ever been - and getting stronger.” He noted that in the past year, more than $1 billion in criminal penalties had been imposed in FCPA- related cases, the most ever in any single 12-month period.
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Executive Summary: Challenges Facing Corporate Ethics and Compliance Programs
3 Dec 2007, Gary Edwards, Robert Reid
The Executive summary of a Research Report from Ethos International, Inc.