Compliance Investigation Simulation

The Compliance Investigation Simulation will be a new one-semester course for two credits enrolling up to eight students. Students will conduct an extended simulated internal investigation based on an anonymous whistleblower report in a fictional pharmaceutical company. Students will function as lead outside counsel conducting an investigation intended to be protected by attorney-client privilege. In the course of the investigation, each team will meet with the client company’s lead compliance lawyer; design an investigation plan; conduct a live online chat with the anonymous reporter; develop case theories; request and review company policies, procedures, and other records; research the law of off-label drug promotion and learn about the relationship between legislation, regulation, subregulatory guidance, and other sources of authority; develop search terms for electronic communications and analyze responsive results; conduct live interviews with witnesses and the alleged wrongdoer; and present their findings in a client-centered counseling session with the company’s general counsel. The work will allow students to hone their research, analytical, writing, presentation, professional collaboration, and problem-solving skills. PREREQUISITE: Introduction to Risk Management and Compliance. NOTE: This course counts toward the 6-credit Experiential Learning requirement. GRADING NOTICE: This course does not offer the CR/NC/H option. RESTRICTION: Students are not permitted to enroll in both the Compliance Policy Clinic and the Compliance Investigation Simulation. ATTENDANCE REQUIREMENT: A student who fails to attend the first class or to obtain permission to be absent from either the instructor or the Registrar will be administratively dropped from the course. Students who are on the wait list are required to attend the first class to be considered for enrollment. Because the course involves regular in-class exercises, some of which are done in teams, and class participation is a significant component of a student's final grade, regular class attendance is essential and thus the course cannot accommodate flexibility in attendance.