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Posted by Jacqueline Tinker on
According to the U.S. Federal Sentencing Guidelines (chapter 8) if an organization has a reasonably effective (not perfect) compliance program in place and they are sanctioned for wrongdoing the government will to give due consideration of the efforts of the compliance program? It’s true! According to a matrix established by the U.S. Sentencing Commission fines and penalties assessed for Fraud, Waste and Abuse can be reduced by up to half if the organization had a reasonably effective compliance program in place during the time period for which the organization is found to have committed fraud, waste or abuse. Considering recoupments...