According to the Federal Sentencing Guidelines, what is required for a corporate compliance program?

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The Federal Sentencing Guidelines emphasize the need for a corporate compliance program to be designed, implemented, and enforced effectively in order to prevent, detect, and remedy violations of law. The effectiveness of a compliance program hinges on its comprehensive nature and commitment throughout the organization, ensuring that employees understand their compliance obligations and the corporate culture supports ethical behavior.

This means that the program should include adequate resources, training, clear policies, and procedures, as well as mechanisms for reporting and addressing compliance issues. An effective program is not merely about having written policies; it involves active monitoring and enforcement to ensure compliance is ingrained in the organizational practices. Thus, a well-executed program serves to mitigate risks and enhance corporate responsibility.

The other options do not align with the guidelines' requirements. For instance, the emphasis is not on the expense of the program, external consultations, or prioritizing employee satisfaction as ends in themselves, but rather on the effectiveness of the program and its role in fostering a culture of compliance and ethics within the organization.

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