Compliance Programs

The goal of college or university administrators should be to create a culture of compliance, centered on a strong compliance program that addresses and coordinates all requirements with which the institution must comply, pursuant to law, regulation, or institutional policy. The Federal Sentencing Guidelines offer incentives to organizations to reduce and ultimately eliminate criminal conduct by providing a structural foundation from which an organization may self-police its own conduct through an effective compliance and ethics program. The existence of an effective compliance and ethics program is one of the factors that mitigates the ultimate punishment of an organization under the Guidelines. Successful models often include clearly developed institutional policies and codes of conduct; effective communication and training procedures; a formal compliance office; a program to monitor compliance; and sanctions or remedial measures for noncompliance. The precise structures and strategies will vary campus-by-campus, but the resources below can be helpful in this process.