Getting It Right, Second Annual General Counsel Roundtable (Dec. 3, 2004), available at http ://www.sec.gov/news/speech/ spch120304smc.htm. 3? See, e.g, ICC RULES ON COMBATING CORRUPTION, supra note 309, at 8. 3°3 See, e.g. US. SENTENCING GUIDELINES § 8B2.1(b)(5)(C); COMPLIANCE 101, supra note 302, at 30