The establishment of an effective, formal compliance program – often associated with an enterprise risk management (ERM) effort – has received an increasing level of attention and focus at institutions across the country. Recognizing the need to improve its compliance efforts, a university general counsel was looking for help to compare the institution's compliance activities with strong industry practices and the Federal Sentencing Guidelines. The university also wanted assistance with developing an enhanced, formal compliance program.
Baker Tilly completed this engagement by reviewing existing policy and procedure documentation and interviewing university leadership and personnel with specific compliance responsibilities. We also compared the institution's existing practices to Federal Sentencing Guidelines and practices within other institutions. We found that the university had provided resources to support specific compliance activities and that its employees were committed to protecting the interest of the institution. However, our review showed that the university lacked a formal, centralized compliance program as described in the Federal Sentencing Guidelines, including proactive involvement at the board and senior management level and procedures for identifying and monitoring compliance activities to assess the effectiveness of current practices and fully evaluate risks.
The university received a detailed report outlining our approach, findings and recommendations. Specifically, we provided concrete and practical recommendations for enhancing and monitoring compliance-related activities throughout the institution, filling gaps and providing increased visibility to the board and senior leaders.
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