Modernly this question has been given special importance by an increasing tendency, especially
under federal law, to employ the criminal law to assure corporate compliance with external legal
requirements, including environmental, financial, employee and product safety as well as assorted
other health and safety regulations. In 1991, pursuant to the Sentencing Reform Act of 1984,21 the
United States Sentencing Commission adopted Organizational Sentencing Guidelines which impact
importantly on the prospective effect these criminal sanctions might have on business corporations.
The Guidelines set forth a uniform sentencing structure for organizations to be sentenced for
violation of federal criminal statutes and provide for penalties that equal or often massively exceed
those previously imposed on corporations.22 The Guidelines offer powerful incentives for
corporations today to have in place compliance programs to detect violations of law, promptly to
report violations to appropriate public officials when discovered, and to take prompt, voluntary
remedial efforts.