Independent Advisory Group to Review Federal Sentencing Guidelines for Organizations
Initiative Marks 20 Years since the Guidelines were Implemented
- Has the private sector responded to the “carrot and stick” incentives in the FSGO by adopting meaningful compliance/ethics programs?
- Can the FSGO’s definition of an “effective” compliance/ethics program be improved?
- Is the FSGO’s credit for effective compliance/ethics programs actually being applied in significant corporate cases?
- Do other enforcement entities, such as the Department of Justice, endorse credit for corporate compliance/ethics efforts, and what happens in actual cases?
- How can an approach for assessing and crediting compliance/ethics programs be more uniformly and effectively applied across other areas of enforcement?
The full membership of the ERC 20th Anniversary Advisory Group is listed below.
Patricia Harned, President, Ethics Resource Center
Win Swenson, Partner, Compliance Systems Legal Group, former Deputy General Counsel, U.S. Sentencing Commission
Advisory Group Members (in alphabetical order):
Scott Avelino, Principal, Compliance Systems Legal Group
Jeff Benjamin, Vice President, Chair, Ethics & Compliance Committee, Novartis Corporation
Judge Ruben Castillo, U.S. District Court, Northern District of Illinois; former Member, U.S. Sentencing Commission
Paul Fiorelli, Professor, Legal Studies, Xavier University
Scott Harshbarger, Senior Counsel, Proskauer; former Massachusetts Attorney General
Ben Heineman, Jr., Senior fellow at Harvard Law School and Harvard Kennedy School; former S.V.P. for Law and Public Affairs, General Electric
Nancy Higgins, Vice President & Chief Ethics and Compliance Officer, Bechtel Corporation
Judge Sven Holmes, Vice Chairman - Legal Risk & Regulatory and Chief Legal Officer, KPMG; former U.S. District Judge
**Michael Horowitz, Partner, Cadawaler, Wickersham & Taft, LLP; formerly Deputy Assistant Attorney General and Chief of Staff in the Criminal Division of the U.S. Department of Justice
Thurgood Marshall, Jr., Partner, Bingham McCutcheon, LLP; formerly Assistant to the President of the United States and Secretary to the Cabinet
Paul McNulty, Partner, Baker & McKenzie, LLP; former Deputy Attorney General, U.S. Department of Justice
Judge Diana Murphy, U.S. Court of Appeals for the Eighth Circuit; formerly Chair, U.S. Sentencing Commission
Joseph E. Murphy, Partner and Vice Chairman of Integrity Interactive Corporation, Compliance Systems Legal Group
Julie O'Sullivan, Associate Dean, J.D. Program; Professor of Law, Georgetown University
Michael Oxley, Partner, Baker Hostetler; formerly Member of Congress (R-OH)
Susan Ponce, Senior Vice President, Special Assistant to the General Counsel, Halliburton Co.
Alexandra Rebay, Senior Vice President, Deputy General Counsel and Chief Compliance Officer, Verizon; formerly Assistant United States Attorney, Southern District of New York
Dan Roach, Vice President, Compliance and Audit, Catholic Healthcare West
Charles Senatore, Head of Corporate Compliance, Fidelity Investments; former Director of the Securities and Exchange Commission's Southeast Region
Larry Thompson, Retired General Counsel, Pepsico, Inc.; former Deputy Attorney General, U.S. Department of Justice
**Mr. Horowitz has taken part in previous Advisory Group meetings, but is now on leave from the Group as he is considered by the U.S. Senate for the Justice Department's Inspector General post.
The Ethics Resource Center (ERC) is a private, nonprofit organization devoted to independent research and the advancement of high ethical standards and practices in public and private institutions. To learn more about ERC, visit http://www.ethics.org.
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