Win Swenson is a Partner at Compliance Systems Legal Group (CSLG), a law firm practicing exclusively in the areas of corporate governance, compliance and ethics.
Win served as Deputy General Counsel at the U.S. Sentencing Commission from 1990 to 1996, leading the unit that developed the federal sentencing guidelines for organizations and establishing the principal model for corporate compliance/ethics programs used in the U.S. He later served on the Sentencing Commission’s advisory group that made recommendations leading to guideline amendments in 2004.
He also previously led the compliance/ethics consulting practice of KPMG LLP in the U.S., has assisted organizations on a broad range of matters relating to compliance/ethics program management and evaluation, served as Counsel to the Senate Judiciary Committee (Senator Edward M. Kennedy’s staff) and was in private law practice with Kaye Scholer Fierman Hays and Handler in Washington, D.C.
In addition to his work with public companies, Win has been retained directly by the U.S. Department of Justice to evaluate the compliance program of a publicly traded company that the government was deciding whether to charge criminally. He also has served on the faculty at the Department of Justice’s National Advocacy Center, where he has provided training to federal prosecutors on how to evaluate compliance programs.
It took a while, but the U.S. Department of Justice is getting ever smarter about analyzing compliance programs. Compliance Systems Legal Group Partner Win Swenson describes this historical trend, explains why it is happening and highlights important takeaways from the DOJ’s recently revised criteria. In 1995, four years after promulgation of the Organizational Sentencing Guidelines – the first law or government policy...
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