In November 2010, updates to the Federal Sentencing Guidelines (FSG) were published that included elements to consider when implementing an effective compliance program. ASIC has created Campus and JPL compliance matrices by evaluating compliance risk areas specific to the Institute. These matrices are used to identify the cognizant policy office/key points of contact and gather information on compliance activities at Campus and JPL. As an ongoing key part of the Institute Compliance Program, ASIC partners with the Office of General Counsel (OGC) and with management at Campus and JPL to document external laws, regulations, and contractual obligations and to identify the office or individual responsible for ensuring compliance with each requirement as well as the control(s) implemented to monitor compliance. On a rotational basis, we perform or update existing compliance assessments of Campus and JPL regarding policies and procedures, monitoring activities, and training; including a gap analysis, to ensure continued adherence.
Federal Sentencing Guidelines (FSG) (Refer to Chapter 8, Section 2)