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Why Are Captives Formed 3
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agreement allegations Antitrust application Attorney attorney-client privilege auditing captive insurance Caremark Circuit City claims client code of ethics commercial insurance company's Compliance Program Guidance compliance program guidelines confidentiality contract corporate court criminal conduct defense detect violations directors disclosure discrimination documents e-recruiting Edison EEOC effective compliance program effective program employees employment enforcement engagement letter factors faith efforts federal Federal Sentencing Guidelines fraud Holder Memorandum illegal activity in-house counsel Indiana internal investigations interview issues law compliance lawyer leniency litigation mediation misconduct Molo monitor obstruction of justice offense officer OIG Compliance Program organization Organizational Guidelines parties person prevent and detect program to prevent prosecutors punitive damages reinsurance relevant risk Sarbanes-Oxley Act Section Sentencing Commission Sentencing Guidelines sexual harassment standards and procedures statute strict liability supra United States Sentencing VICARIOUS LIABILITY violations of law Wallance warranties witness wrongdoing