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here - HUMBOLDT-VIADRINA School of Governance

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Example for context 2<br />

• US Sentencing Guidelines’ conditions for probation for organization allows to require a supervised<br />

establishment/enhancement <strong>of</strong> an internal compliance program (example: Kellogg Brown & Root LLC agreed<br />

in 2009 to retain an external compliance monitor in plea agreement for organizational probation)<br />

Sources: http://www.ussc.gov/Guidelines/2010_guidelines/Manual_HTML/8d1_4.htm and http://www.justice.gov/criminal/fraud/fcpa/cases/kelloggb/02-11-<br />

09kbr-plea-agree.pdf<br />

8

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