Criminal liability can attach to an organization whenever an employee of the organization commits an act within the apparent scope of his or her employment, even if the employee acted directly contrary to company policy and instructions. An entire organization, despite its best efforts to prevent wrongdoing in its ranks, can still be held criminally liable for any of its employees' illegal actions. Consequently, the United States Sentencing Commission (the Commission), when promulgating the sentencing guidelines, attempted to alleviate the harshest aspects of this institutional liability by incorporating preventive and deterrent aspects of systematic compliance programs. As a result, the Commission mitigated the potential range of fines if an organization can demonstrate that it had put in place an effective compliance program. It outlines key criteria for an effective compliance program.