Compliance history

1996) and United States Sentencing Commission, The Federal Sentencing Guidelines for Organizations, Section 8B2.1.

In late 1999, international business Seaboard Corporation (Seaboard) began an investigation of a division controller for booking improper entries in the financial statements.

The controller subsequently confessed in July 2000 that she had been making these false accounting entries for five years resulting in over $7 million in accounting discrepancies.

2001. "A Conversation with Kristin Jenkins, Compliance and Quality Officer." Compliance Today 3(5): 13–19.

[xlvii] Diana E. Murphy, “The Federal Sentencing Guidelines for Organizations: A Decade of Promoting Compliance and Ethics,” Iowa Law Review, 2002, 710.

[lvi] United States Deputy Attorney General Larry Thompson, Principles of Federal Prosecution of Business Organizations, January 2003, 37 – 38, http://www.americanbar.org/content/dam/aba/migrated/poladv/priorities/privilegewaiver/2003jan20_privwaiv_dojthomp.authcheckdam.pdf.

The emendation of those guidelines in 2004 reflected the need for corporate boards to demonstrate knowledge of compliance programs and fulfillment of oversight responsibilities as part of monitoring the effectiveness of companies’ compliance and ethics programs.

[xxxiv] Martin T. Biegelman and Joel T. Bartow, Executive Roadmap to Fraud Prevention and Internal Control: Creating a Culture of Compliance” (Hoboken, NJ: John Wiley & Sons, 2006), 318.

[xxv] Martin T. Biegelman with Daniel R. Biegelman, Building a World-Class Compliance Program, (Hoboken, NJ: John Wiley & Sons, Inc., 2008), 67.

Every organization, regardless of scope or industry, must have an effective compliance program as outlined by the 2010 Federal Sentencing Guidelines Manual.