It would be two coaches who could possibly considered criminal. Sandusky obviously, but I think you can say that Paterno is a criminal. Covering up what happened can be considered criminal.
I think it can also fall under NCAA rules about not reporting a crime. Plus the NCAA makes up rules at whim, so it is possible that they could have the power to punish Penn St. I am not saying they should at this point, but I think they could if they wanted.
The NCAA could claim there was a lack of institutional control that led to these events. They could even boot strap it with all the player arrests that have occurred in the last decade. And even though Paterno is gone, the current coaches all worked under Paterno, so they still follow his basic methods and teachings. The fact that there are new incoming players, students and/or staffs has never influenced the NCAA's decisions on how to punish a program. They don't consider that these new people aren't the wrong doers when deciding punishment. They just do what they do. I don't expect the NCAA to step in and assert their authority and I don't think they need to, but they could if they chose so.