Department of Justice's Compliance Framework Influences White-Collar Sentencing Reductions
The Department of Justice (DOJ) has been utilizing a seven-pillar framework to evaluate corporate compliance programs, which is now being applied by white-collar defendants to demonstrate personal rehabilitation. This framework includes written policies, ethical leadership, training and communication, monitoring and auditing, internal reporting systems, enforcement and discipline, and continuous improvement. In a securities fraud case, a former compliance officer used this framework to create an ethics rebuild memo, which was instrumental in reducing his sentence. The approach is seen as powerful in court as it shows structured transformation rather than mere sentiment. This method has been successfully used in various cases, including a notable sports betting case, to achieve significant sentence reductions.