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Understanding the U.S. Federal Sentencing Guidelines and What They Mean for Your Organization

The 2004 Revised U.S. Federal Sentencing Guidelines Require Ethics Training for All Employees.  Excerpts from the Federal Sentencing Guidelines are as follows:

  • “To have an effective compliance and ethics program…an organization shall…promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.”  U.S. Sentencing Guidelines, §8B2.1(a),(a1),(a2)
  • “Section 8B2.1(b)(4) makes compliance and ethics training a requirement, and specifically extends the training requirement to the upper levels of an organization, including the governing authority and high-level personnel, in addition to all of the organization’s employees and agents, as appropriate.”  Commentary, 2004 Federal Sentencing Guidelines
  • “[Section 8B2.1(b)(4)] establishes that this communication and training obligation is ongoing, requiring “periodic” updates.”  Commentary, 2004 Federal Sentencing Guidelines
  • “The organization shall take reasonable steps to communicate periodically and in a practical manner its standards and procedures, and other aspects of the compliance and ethics program, to [all personnel, including high-level personnel, members of the governing authority, and others] by conducting effective training programs and otherwise disseminating information appropriate to such individuals’ respective roles and responsibilities.”  U.S. Sentencing Guidelines, §8B2.1(b)(4)(A)

US Federal Sentencing Guidelines

RedHawk’s Ethics and Compliance programs meet all of the U.S. Federal Sentencing Guidelines – find out how you can bring effective ethics to your organization by scheduling a demo or calling us at 732-440-1600.