At the end of April, the US Sentencing Commission submitted new amendments to the Federal Sentencing Commission, (the agency that sets out sentencing guidelines for Federal courts and reports to Congress) laying out ways for companies to reduce their liabilities when employees are involved in criminal behavior. In the past these liabilities have been determined by the amount of money involved and the use of a scoring system based on six factors, which determine the multiplier of the amount to be fined.

These factors are: corporate involvement in or tolerance of criminal activity; corporate history of misconduct; whether the misconduct violated a judicial order or injunction; whether the corporation directly or indirectly obstructed justice; the effectiveness of compliance and ethics programs in place at the time of the offense; and whether the corporation self-reported, cooperated, and has accepted responsibility.