On April 30, 2010, the U.S. Sentencing Commission sent Congress proposed amendments to the U.S. Sentencing Guidelines. The amendments include important changes to the requirements that

an organization must meet in order to have an "effective compliance and ethics program" and, thereby, to potentially

mitigate any sentence imposed in the event of a criminal prosecution. The most significant changes clarify how an

organization's senior compliance personnel should interact with the Board of Directors and address how an organization must respond when it discovers criminal conduct. Richard W. Westling and Chelsea S. Rice of Ober|Kaler look at the proposed amendments in this alert.