What does the 'E' in your 'C&E program' stand for?

Jeffrey M. Kaplan (jkaplan@kaplanwalker.com) is a Partner with Kaplan & Walker LLP in Princeton, New Jersey, USA.

In the beginning—when Chapter Eight of the Federal Sentencing Guidelines went into effect in 1991—there were mostly ethics officers. By the early to mid-2000s, having a compliance & ethics (C&E) officer had become the predominant model. Among other things, this was in response to the enactment of the Sarbanes–Oxley Act in 2002 and amendments to Chapter Eight in 2004.

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