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“Corporate executives may be tempted …to invest fewer resources in their compliance efforts. …. I caution you in this regard. The Department is looking carefully at lapses - both past, present, and future - in corporate compliance.”

– Lanny A. Breuer, Assistant Attorney General, Criminal Division, U.S. Department of Justice

 

Our Team

Winthrop M. Swenson, Partner

Win Swenson is a managing partner in Compliance Systems Legal Group (CSLG), a law firm specializing in corporate ethics and compliance, globally.

Experience

As Deputy General Counsel at the U.S. Sentencing Commission (1990-1996), Mr. Swenson headed the unit that developed the federal sentencing guidelines for organizations, which are widely viewed as establishing the principal model for corporate compliance/ethics programs in the United States, and to some extent abroad. More recently, Mr. Swenson was a member of the Advisory Group that made recommendations to the Sentencing Commission on ways to improve the organizational guidelines, leading to amendments adopted in 2004.

From 1996-2000, Mr. Swenson led the compliance/ethics consulting practice of KPMG LLP in the U.S.

Both at CSLG and in his prior consulting work, Mr. Swenson has assisted organizations on a very broad range of matters relating to compliance/ethics program management and evaluation. This work has included:

• Serving as an independent third-party monitor or consultant to companies pursuant to compliance-related agreements with U.S. governmental agencies (including the Department of Justice, SEC, Department of Defense/Air Force, General Accounting Office and the Agency for International Development).
• Conducting on-the-ground evaluations of compliance/ethics programs in about 30 countries.
• Conducting compliance/ethics training for the boards of directors of some of the world’s most recognized companies.

Mr. Swenson’s professional background also includes serving as Counsel to the Senate Judiciary Committee, and private law practice with Kaye Scholer Fierman Hays and Handler in Washington, D.C.

Work with Department of Justice

In addition to his work with public companies, Mr. Swenson has been retained 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.

Mr. Swenson 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.

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