Cross Industry Cross Compliance - Governance, Risk, and Compliance Topic for Oracle Applications - page 339

The following diagram shows the encryption and decryption hierarchy:

Master Key

Encrypts

Subkey
Cipher Text 1
)p(i*

Subkey
Cipher Text 2
&i*4$

Subkey 1
1234

Subkey 2
4567

Payment
Instrument 1
234 567

Payment
Instrument 3
567 123

Encrypts

Payment
Instrument Cipher
Text $5T^Y

Payment
Instrument Cipher
Text e$5R6

Not Stored in
Database

Federal Sentencing Guidelines
On May 1, 1991, as an extension of the Sentencing Reform Act, the United States
Sentencing Commission submitted the Federal Sentencing Guidelines for
Organizations ( FSGO ) to the Congress. It is a set of standards that govern the
sentences the federal judges impose on organizations convicted of federal crimes.
Enacted on November 1, 1991, core to the guidelines was the Commission's
intent to "prevent and deter organizational wrongdoing" through its design of
the organizational sentencing guidelines. These guidelines describe the elements
of an organization's compliance and ethics program that are required to be
considered for eligibility for a reduced sentence if convicted. Revisions to the
Federal Sentencing Guidelines for Organizations that took effect in November 2004
contain requirements for companies to heighten their efforts to detect and prevent
violations of law, and to implement efforts to establish an ethical culture.

The amended guidelines stated the need for directors and executives to take
an active role in the management of its compliance and ethics program and the
importance of promoting an organizational culture that is compliant with the
law and demonstrates ethical culture. The amended guidelines outline minimum
requirements for an effective compliance and ethics program and the amended
FSGO has become synonymous with an effective compliance program.