Our Team

Winthrop M. Swenson, Partner

As Deputy General Counsel at the U.S. Sentencing Commission (1990-1996), Win headed the unit that developed the federal sentencing guidelines for organizations, which are widely viewed as establishing the principal model for corporate compliance/ethics programs in the United States, and to some extent abroad.  More recently, Win was a member of the Advisory Group that made recommendations to the Sentencing Commission on ways to improve the organizational guidelines, leading to amendments adopted in 2004.

From 1996-2000, Win led the compliance/ethics consulting practice of KPMG LLP in the U.S.  Both at CSLG and in his prior consulting work, Win has assisted organizations on a very broad range of matters relating to compliance/ethics program management and evaluation.  This work has included:

  • Serving as an independent third-party monitor or consultant to companies pursuant to compliance-related agreements with U.S. governmental agencies (including the Department of Justice, SEC, Department of Defense/Air Force, General Accounting Office and the Agency for International Development).
  • Conducting on-the-ground evaluations of compliance/ethics programs in about 30 countries.
  • Conducting compliance/ethics training for the boards of directors of some of the world’s most recognized companies.

Win’s professional background also includes serving as Counsel to the Senate Judiciary Committee, and private law practice with Kaye Scholer Fierman Hays and Handler in Washington, D.C.

In addition to his work with public companies, Win has been retained by the U.S. Department of Justice to evaluate the compliance program of a publicly traded company that the government was deciding whether to charge criminally.

Mr. Swenson has also served on the faculty at the Department of Justice’s National Advocacy Center, where he has provided training to federal prosecutors on how to evaluate compliance programs.

Win obtained his J.D. from New York University School of Law where he was on the law review, a member of the Root-Tilden Scholarship Program, awarded the John Norton Pomeroy Award for Scholarship and elected to the Order of the Coif.  He obtained his B.A. from Middlebury College where he was a College and Independent Scholar.  He also spent a year at Harvard University as a Visiting Undergraduate.  He is admitted to practice in New York (inactive) and the District of Columbia (active).

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