Seven Elements of an Effective Compliance Program

The United States Sentencing Guidelines for Organizations is a federal law pertaining to the assessment of damages in cases of fraud against the government. The Guidelines list seven essential requirements of an effective compliance program. The following are ways the UT Dallas Compliance Program has addressed the seven elements:

  1. Implementing written policies and procedures
  2. Designating a compliance officer and compliance committee
  3. Conducting effective training and education
  4. Developing effective lines of communication
  5. Conducting internal monitoring and auditing
  6. Enforcing standards through well-publicized disciplinary guidelines
    • Consequences levied consistently regardless of the employee’s stature within the organization. Enforcement consistent with appropriate disciplinary action.
  7. Responding promptly to detected problems and undertaking corrective action
    • Hotline procedures require two weeks for action; elevation to VP/President