Compliance and Enforcement for Organizations

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Status Details

At its meetings on October 13 and October 22-23, 2020, the Council approved §§ 6.01-6.20 of Chapter 6 of Council Draft No. 4, which included principles common to enforcement by criminal prosecutors and civil enforcement officials, as well as criminal enforcement policy for misconduct by organizations. The approval excludes new material on joint defense agreements to be drafted by the Reporters in accordance with the discussion at the meeting and included in the next Council Draft. The Council also discussed Chapter 4, Compliance Risk Management, but no vote was taken. The Reporters will revise the Chapter in accordance with the discussion for the Council’s consideration in January 2021.

At its meeting in New York City on October 17 and 18, 2019, the Council approved §§ 5.09 and 5.18-5.38 of Chapter 5 on Compliance, as well as the definitions in Chapter 1 that were not previously approved. (Portions of Chapters 1 and 5 were approved at the 2019 Annual Meeting.) There was insufficient time to complete the discussion of Chapter 4 on Risk Management and Chapter 6 on Enforcement. The Reporters will work with an ad hoc group of Council members to revise Chapter 6 in accordance with the discussion.

Chapter 2 (Subject Matter, Objectives, and Interpretation), Chapter 3 (Governance), and portions of Chapters 1 (Definitions) and 5 (Compliance) were approved by membership at the 2019 Annual Meeting.

All draft approvals are subject to the discussion at the meeting and usual editorial prerogative.

Crisis Management Panel Discussion (May 2017)