Compliance on campus: Applying DOJ’s corporate compliance guidance in an academic environment

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In the ever-evolving landscape of compliance, the U.S. Department of Justice (DOJ) has intensified its scrutiny of corporate and executive liability, underscoring the critical role of effective compliance programs in preventing, detecting, and remediating misconduct. Lisa Monaco, the deputy attorney general, and other senior DOJ officials have emphasized the significance of robust compliance measures in mitigating legal risks and fostering ethical business practices.

Monaco, acknowledging DOJ’s commitment to accountability, stated, “With a combination of carrots and sticks—with a mix of incentives and deterrence—we’re giving general counsels and chief compliance officers the tools they need to make a business case for responsible corporate behavior.”[1] She elaborated that “companies should feel empowered to do the right thing—to invest in compliance and culture, and to step up and own up when misconduct occurs.” Kenneth Polite, former assistant attorney general for the Criminal Division, echoed this sentiment: “We closely evaluate corporate compliance programs during our corporate investigations and after our corporate resolutions, and give significant credit to companies that build strong controls to detect and prevent misconduct.”[2]

This article delves into the latest guidance—updated in March 2023—provided in the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs, offering valuable insights for compliance employees at colleges and universities.[3] Although the guidance comes from DOJ’s Criminal Division, it is equally relevant to civil matters; compliance programs aligned with these guidelines will be recognized as the gold standard by many federal regulators in addition to DOJ.

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