Your English writing platform
Discover LudwigExact(20)
In 2005, when KPMG signed a deferred prosecution agreement stemming from its marketing of illegal tax shelters, it agreed to maintain an effective compliance and ethics program.
Perhaps less noticed is the Yates Memorandum's silence regarding the benefits of an effective compliance program, which was featured prominently in every preceding policy memorandum.
Under the guidelines, issuers can significantly reduce their "culpability score" for insider trading and other offenses by having an effective compliance and ethics program in place.
1523, 1528 n. 37 (2009) ("Companies can reduce their culpability score by three points when they have in place an effective compliance and ethics program".).
To be sure, the Yates Memorandum was intended to expound on what gives rise to cooperation credit, so it naturally does not address what mitigating consideration DOJ affords an effective compliance program under the Justice Manual, seemingly leaving undisturbed the mitigating credit derived from an effective compliance program.
Regulators demand the impossible when they require issuers to design and implement an effective compliance program to guard against insider trading, a crime that neither Congress nor the SEC has defined with any specificity.
Similar(40)
The officials wrote that the council had been found to be out of compliance with federal standards as recently as February 2017, and therefore does not meet the requirement that an agency demonstrate effective compliance for at least two years before seeking initial recognition.
A theoretical model, somewhat analogous to an extension of the classical shear lag model to incorporate elastic-plastic interlayers, is proposed to predict the friction response as a function of effective compliance.
Signing, ratifying and passing legislation to implement an international agreement with effective compliance and enforcement mechanisms demonstrates a longer-term commitment not easily undone following the next election.
In the enforcement of federal and state statutes, injunctions are sought with far greater frequency than are criminal penalties as a means of obtaining effective compliance.
Effective compliance played a role in compensating the error between the nominal rack force and the actual rack force.
Write better and faster with AI suggestions while staying true to your unique style.
Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com