Are U.S. colleges and universities complying with the FCPA?

Many initial discussions of the FCPA with the leadership of U.S. colleges and universities (Schools) begin with something like the following:

1. we would never engage in corruption such as bribery
2. we are not-for-profit and do not need to consider unethical activity
3. we are not that international, other than having a few foreign students, and
4. we are among the most heavily regulated and scrutinized activities and do not need more policies and procedures.