Abstract: The basic functions of the criminal compliance program being preventing corporate crimes, many cases of corporate compliance failures in practice have aroused doubts about its effectiveness, which mainly includes: the conflict between the effectiveness and the basic functions of the criminal compliance program, compliance being reduced to a mechanism for exempting with money bribery, superficial features being easy to imitate, and increasing the burden on small and medium-sized enterprises. In fact, corporate criminal compliance programs fail in practice mostly because they are only effective in form but ineffective in substance. Substantial effectiveness is the core of the effectiveness of the criminal compliance program. When external supervision is unable to ensure substantial effectiveness, stimulating the endogenous motivation from within the enterprise is a powerful measure to prevent paper programs. This needs to focus on informal norms that have a greater impact on substantive effectiveness. In addition, clarifying the boundaries of the effectiveness of the criminal compliance program and the criteria for degree division is the necessary "survival way" for enterprises under external supervision.

Key words: criminal compliance program, effectiveness, substantively effective, formally effective, organizational atmosphere