Seven Elements of an Effective Compliance Program

The Guidelines

Guidance and directions for establishing and maintaining an effective ethics and compliance program are outlined in Chapter 8 of the Federal Sentencing Guidelines.  The Guidelines set two foundational requirements, along with seven elements.

  1. An organization “shall exercise due diligence to prevent and detect criminal conduct;” and
  2. An organization “shall otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.”

 

 

The Seven Elements

1. Implementing written policies & procedures

All policies can be found in the Policy Library. 
2. Governance & oversight

Designated Compliance Officer; Brittney Alls, JD

ACERM Steering Committee

Compliance Advisory Committee (in development)
3. Effective training & education

 
4. Effective lines of communication

Various methods to report via the Hotline
5. Internal auditing & monitoring

 
6. Enforcement & disciplinary guidelines

 
7. Prompt response