Yesterday, my FCPA Blog colleague, Dick Cassin, posted Memo to law schools: The world needs compliance officers, in which he implored law schools to train J.D. candidates in compliance. He also noted that while a few schools teach the FCPA and white collar courses, compliance is not taught in law schools.
While I agree with Dick’s overall argument, I am happy to report that GW Law received this memo in 2009, when we created a course which teaches anti-corruption, ethics and compliance.
At GW Law, we have created a seminar that is designed not only to make students think about legal and policy issues involving anti-corruption statutes (FCPA, False Claims Act, suspension & debarment, domestic corruption statutes, etc.), but to consider how anti-corruption, ethics and compliance work in the real world. We implemented this dual approach to anti-corruption and ethics because we want our students to be as “practice ready” as possible when they graduate.
We have developed a curriculum that is designed to teach students how to become anti-corruption compliance professionals. For example, in our course, students are required to develop a corporate compliance system. Specifically, students develop corporate compliance policies and procedures, then present their programs to the class. We assign this exercise in addition to dedicating two classes to compliance best practices and the development of a corporate culture of ethics and compliance.
We are also training our students to become savvy anti-corruption practitioners. With the help of local anti-corruption experts/guest lecturers (our location in Washington, DC is a boon), we dedicate numerous classes to teaching students how to operate in “real-world” anti-corruption scenarios.
A few weeks ago, students were assigned an exercise based loosely on the former Virginia Governor’s corruption scandal. Through this exercise, students learn about prosecutorial discretion, advocacy, negotiations, and cooperation with government officials. As one student told me after class, while most of her legal education has focused on litigation strategies, in our class, she has learned that cooperation is sometimes the better strategy.
Finally, in a few weeks a Suspension & Debarment official will visit our class to oversee students walking through a suspension & debarment proceeding. Former students have informed me that this exercise has taught them unforgettable lessons about how to represent a client in a suspension and debarment proceeding.
Having taught this class for the past six years, I have seen former students graduate to become successful anti-corruption and compliance practitioners at companies, law firms, consulting services, and even international organizations. And while I agree that law students across the country could similarly benefit from a course like this, I hope this post serves as an important reminder that some schools have been training future compliance professionals for quite some time. More importantly, I hope that existing courses may serve as a model for schools that want to provide students with the tools necessary to be successful anti-corruption and compliance professionals.
Jessica Tillipman is a Senior Editor of the FCPA Blog and Assistant Dean at The George Washington Univeristy Law School.