Chapter 2: Foundational Materials and Program Infrastructure

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The History of the Organizational Sentencing Guidelines and the Emergence of Effective Compliance and Ethics Programs

1Judge Ketanji Brown Jackson, Esq. is a United States district judge for the District of Columbia and the former vice chair of the United States Sentencing Commission. Kathleen Cooper Grilli, Esq. is general counsel of the United States Sentencing Commission (hereinafter referred to as the Commission or USSC). The views expressed herein are the authors’ own and do not necessarily represent the official position of the USSC. The authors gratefully acknowledge the assistance of Linda Baltrusch, James Strawley, Tobias Dorsey, Jessica Warnement, and Carrie Wilson. Any Commission materials cited herein are available to the public according to the terms of the USSC’s public access policy. See