This excerpt is taken from our interview of Winthrop Swenson, who we spoke to about working as an outside advisor, his experiences as Sentencing Commission Deputy General Counsel, and his work with a Big Four firm
At the Commission, the job was to write a series of laws that would apply when organizations (not just corporations but including corporations) are sentenced in federal court for crimes. There was no prior existing law of any kind that dealt with this specific area, so we had to create a brand new scheme and framework for what sentencing of corporations should look like. We got input from the private sector and from governmental entities, and came up with the framework that included a model for compliance and ethics programs. That took quite a while and many, many drafts, on which we got public and informal comment along the way. When the Guidelines came out, they were regarded as fairly experimental, so I spent a lot of time going out and talking to particularly the business community about the Guidelines (what their intent was) to make sure that everybody had gotten the word.
Winthrop Swenson's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.
(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)
