Issue 4: Seven Elements to Stronger Compliance. How Leadership Oversight Shapes Integrity and Accountability on Campus (September 2025).
What is an effective compliance program?
An effective compliance program is essential for safeguarding both the mission and reputation of higher education institutions. The U.S. Sentencing Commission defines an effective compliance and ethics program as one designed to ensure adherence to applicable legal requirements, with mechanisms to prevent, detect, and correct violations and wrongdoing within an organization. The U.S. Department of Justice (DOJ) released its third iteration of the Evaluation of Corporate Compliance Programs (ECCP) in June 2020, and in September 2024 issued additional guidance to further clarify expectations for corporate compliance programs. This updated guidance outlines the questions DOJ investigators ask when assessing the effectiveness of compliance efforts and serves as a critical roadmap for risk and compliance professionals.
What are the elements of an effective compliance program?
The seven elements of an effective compliance program apply to all industries, though they originated in the healthcare industry back in the 1990s. Since then, many variations have emerged. The Society of Corporate Compliance and Ethics (SCCE) and other organizations have published and copyrighted their own versions ranging from six to twelve elements. Regardless of the format, the seven elements remain the gold standard and a core framework for developing or maintaining an effective program.
The key seven elements include:
- Standards, Policies, and Procedures – Establishing clear expectations for behavior and compliance through structured policies that provide consistency and assurance.
- Leadership Oversight – Ensuring active involvement and commitment from senior administrators and boards, supported by dedicated oversight from a Compliance Officer.
- Education and Training – Providing ongoing, accessible compliance training and education for all employees.
- Monitoring and Auditing – Conducting regular reviews of processes and activities to identify potential risks.
- Reporting and Investigation – Maintaining safe, confidential reporting channels and ensuring timely, fair investigations.
- Enforcement and Discipline – Applying consistent consequences for violations, regardless of role or position.
- Response and Prevention – Addressing issues effectively, taking corrective action, and implementing changes to prevent reoccurrence.
Why is leadership oversight so important?
Among these seven elements, leadership oversight is the most critical for higher education. A compliance program cannot thrive without visible, ongoing engagement from presidents, boards, and senior administrators. Effective oversight means more than signing off on policies—it requires reviewing reports, asking questions, dedicating resources, and reinforcing compliance as a strategic priority. When leaders model accountability, they establish the “tone at the top,” demonstrating that compliance and ethics are not optional but central to the university’s mission.
By embracing oversight and supporting all seven elements, leadership ensures that compliance programs are not simply policies on paper but living systems that build trust across the academic community. Strong compliance programs reduce legal and financial risk while reinforcing the institutional credibility, safeguarding its values, and protecting the university’s future.
Among these seven elements, leadership oversight is the most critical for higher education. A compliance program cannot thrive without visible, ongoing engagement from presidents, boards, and senior administrators. Effective oversight means more than signing off on policies—it requires reviewing reports, asking questions, dedicating resources, and reinforcing compliance as a strategic priority. When leaders model accountability, they establish the “tone at the top,” demonstrating that compliance and ethics are not optional but central to the university’s mission.
By embracing oversight and supporting all seven elements, leadership ensures that compliance programs are not simply policies on paper but living systems that build trust across the academic community. Strong compliance programs reduce legal and financial risk while reinforcing the institutional credibility, safeguarding its values, and protecting the university’s future.
Test your knowledge on these questions!
Answer: True! Having a compliance structure and program is essential to mitigate risks related to federal and state regulations, institutional policies, etc. Answer: C. Answer: B. Leadership oversight means active engagement: reviewing reports, asking questions, dedicating resources, and modeling accountability—not just signing policies. Answer: B. Leadership oversight is critical because it sets the “tone at the top,” showing that compliance is a visible, strategic priority and central to the institution’s mission. Answer: D. The U.S. Department of Justice (DOJ) Evaluation of Corporate Compliance Programs (ECCP) guidance states: prosecutors evaluating the effectiveness of a compliance program are instructed to reflect on: “the extent and pervasiveness of the criminal misconduct; the number and level of the corporate employees involved; the seriousness, duration, and frequency of the misconduct; and any remedial actions taken by the corporation, including, for example, disciplinary action against past violators uncovered by the prior compliance program, and revisions to corporate compliance programs in light of lessons learned.” Prosecutors should also consider “the effectiveness of the company’s risk assessment and the manner in which the company’s compliance program has been tailored based on that risk assessment” and whether its criteria are “periodically updated.” The ECCP in Criminal Antitrust Investigations guidance includes a section on Elements of an Effective Compliance Program, which outlines nine factors prosecutors should consider when evaluating the effectiveness of a compliance program. These elements provide a standard structure and framework for compliance programs…keep in mind that every compliance program will look different from other compliance programs. The factors include: the design and comprehensiveness of the program; the culture of compliance; responsibility for, and resources dedicated to, compliance; risk assessment techniques; compliance training and communication to employees; monitoring and auditing techniques, including continued review, evaluation, and revision of the compliance program; reporting mechanisms; compliance incentives and discipline; and remediation methods. Answer: True! It should be considered.
Interested in learning more about these guidelines? Check out the following: U.S. Sentencing Commission Federal Sentencing Guidelines Manual 2024. Effective Compliance & Ethics Program. https://www.ussc.gov/sites/default/files/pdf/guidelines-manual/2024/GLMFull.pdf
U.S. Department of Justice Criminal Division, Evaluation of Corporate Compliance Programs, Updated September 2024. https://www.justice.gov/criminal/criminal-fraud/page/file/937501/dl
U.S. Department of Justice Antitrust Division, Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations, Updated November 2024. https://www.justice.gov/d9/2024-11/DOJ%20Antitrust%20Division%20ECCP%20-%20November%202024%20Updates%20-%20FINAL.pdf
Guiding Elements of the UW Compliance Framework https://www.wisconsin.edu/compliance/guiding-elements/
Check out these additional UW resources: https://www.wisconsin.edu/compliance/download/Building-an-Effective-Compliance-Program-in-an-Ever-Changing-Landscape-Checklist.pdf https://www.wisconsin.edu/compliance/download/OCRM-Checklist-DOJ-Evaluation-of-Compliance-Programs.pdf https://www.wisconsin.edu/compliance/download/OCRM-Resource-DOJ-Updated-Criteria-for-Evaluating-Compliance-Programs.pdf
Sources:
U.S. Sentencing Commission. Federal Sentencing Guidelines. Washington: U.S. Sentencing Commission. Retrieved from https://www.ussc.gov/guidelines/2018-guidelines-manual-annotated
U.S. Department of Justice. Evaluation of Corporate Compliance Programs. Washington: U.S. Department of Justice, June 2020 (third edition); updated September 2024. Retrieved from https://www.justice.gov/criminal-fraud/page/file/937501/download