 The paper finds that the culpability score calculations made pursuant to the guidelines, which are designed to calibrate a company's ultimate penalty with its level of wrongdoing, are not statistically significant in determining penalties. Instead, it appears a norm has developed at the Department of Justice giving an almost uniform 25% discount off the low end of the fine range, regardless of a company's culpability, they write. For the Corporate Crime Reporter, I'm Russell Mulcahy.