"Speak the truth. Transparency breeds legitimacy."
John C. Maxwell
This month we continue our review of the events of 2024 with a focus on the Fraud & Ethics Category. Since our inception of this newsletter, occupational fraud – situations where employees use their position to commit misappropriation – has been the most frequent item seen in this category. While occupational fraud continues to lead the way in 2024, coming in a close second is research related topics. These come in a variety of ways: grant fraud, foreign disclosure issues, false claims, and more. The third most frequent item we see are those stories related to conflicts of interest.
2024 Fraud & Ethics 1. Occupational Fraud 2. Research Related Issues 3. Conflicts of Interest
This category takes on increased importance in the current national environment of intense scrutiny of how funds are expended. We’ve also seen an overall increase in reports coming to our anonymous reporting system over the past year, with more than 100% growth in reports received from 2023 to 2024. We are on course after the first quarter of 2025 for yet another increase in the number of reports received. While not all reports are substantiated by our office, it does indicate a willingness by employees and others to report things that they see as issues. No matter what your opinion is of DOGE and those efforts to find fraud and wasteful spending, similar scrutiny will make its way down to institutions in the coming year. Therefore, the need to emphasize ethics and compliance has never been greater.
The stories we link in this category all essentially come down to individuals who make poor decisions, which leads to the question: how can we increase the odds of ethical decision making? We offer three suggestions that might help improve the odds of wise decision making at your institution:
Have a board approved Code of Conduct/Ethics. This sends the message from the very top that ethical behavior is expected at your institution. You can see AU’s board approved code here.
Ensure training is offered on both policies and ethics. While training in these areas is often optional, institutions might consider making ethics training mandatory going forward.
Have a way people can report wrongdoing they see. The threat of detection is a powerful motivator for not committing wrongdoing.
While this topic is vitally important, as always, there are a multitude of risks facing our industry. We invite you to review this month's news stories with a view toward proactively managing risk in your sphere of influence. We welcome your comments and suggestions.
Mar 22: Cyberattack: A hacker took over NYU’s website for at least two hours Saturday morning to expose over 3 million applicants’ names, test scores, majors and zip codes, as well as information related to family members and financial aid dating back to at least 1989. The university’s website was restored at around noon. The hacked page displayed three charts with what the group claims to be NYU’s average admitted SAT scores, ACT scores and GPAs for the 2024-25 admissions cycle. The group argued that despite the Supreme Court’s takedown of affirmative action in 2023, "NYU continued anyway," showing that the average admitted test scores and GPAs for Asian and white applicants were higher than those who identify as Hispanic or Black. (link)
Mar 20 : Hacking: [A] Former NFL and University of Michigan assistant football coach hacked into the computer accounts of thousands of college athletes seeking intimate photos and videos, according to an indictment filed Thursday. [The coach], who worked for the Baltimore Ravens before joining Michigan’s staff in 2021, was charged with 14 counts of unauthorized computer access and 10 counts of identity theft. The indictment was filed in federal court in Detroit. [He] was fired in 2023 as Michigan’s co-offensive coordinator after failing to cooperate with the school’s investigation of his access to computers. From 2015 to 2023, [the coach] gained access to the databases of more than 100 colleges and universities that were maintained by a third-party vendor, Keffer Development Services, and then downloaded personal information and medical data of more than 150,000 athletes, the indictment states. (link)
Mar 05: Data Breach: On March 3, 2025, Loyola University Maryland ("Loyola") filed a notice of data breach with the Attorney General of Massachusetts after discovering that an unauthorized party was able to access portions of the organization’s computer network. In this notice, Loyola explains that the incident resulted in an unauthorized party being able to access consumers’ sensitive information, which includes their names and Social Security numbers. Upon completing its investigation, Loyola began sending out data breach notification letters to all individuals whose information was affected by the recent data security incident. (link)
Fraud & Ethics Related Events
Mar 24 : Foreign Ties: A new report from a nonprofit and nonpartisan government watchdog is shedding light on the tens of billions of dollars that have poured into U.S. universities in recent years, including $20 billion to some of the most prestigious universities in the country. The report, produced by Americans for Public Trust and released this week, found that $60 billion in foreign gifts and contracts were funneled into American colleges and universities, including $20 billion alone to elite schools like Harvard, Yale, and others. Within that total, $795 million came from nations that are long-standing adversaries to the United States, including China, Russia, Venezuela and Yemen. "Alarmingly, many of these schools are also top research universities that handle sensitive information and intellectual property," the study states. (link)
Mar 07: Financial Mismanagement: An audit from Oklahoma State University shows about $41 million in state-appropriated funds were not properly distributed over a two-and-a-half-year period. The money, meant for education and research, was mixed with other funds or misused for unrelated expenses. The review found unauthorized transfers to the Innovation Foundation at OSU and expenditures unrelated to their intended purpose. "Such actions in some cases violated state laws and policies, thereby posing financial and reputational risks to the institution," according to the audit. Simply put, OSU distributed taxpayer money in ways unauthorized by Oklahoma’s state legislature, which determines how state funds are assigned. (link)
Mar 01: Occupational Fraud: A UConn faculty member is charged with larceny after she allegedly used university and grant funds for personal travel and related personal expenses in violation of UConn’s travel policy, and more, according to the university. The travel in question, including allegedly to Ireland and Disney World, reportedly "involved costs related to transportation, lodging, meals, and other expenses. The travel was presented by the faculty member in advance for approval and after the fact as being undertaken entirely in support of research and teaching, which was later determined through the investigation to be inaccurate," according to UConn. (link)
Compliance/Regulatory & Legal Events
Mar 24 : Title IX: Former University of Michigan assistant football coach Matt Weiss pleaded not guilty to federal charges Monday as two women filed a class-action lawsuit alleging they were victims of a scheme to access private student accounts. Weiss was charged in a 24-count indictment last week after federal prosecutors accused him of accessing the digital accounts of 3,300 student-athletes to download their intimate photos and videos. He pleaded not guilty on all charges and was released on a $10,000 unsecured bond, court records show. Their suit alleges multiple violations of the law by Weiss and the other parties, including violations of Title IX protections, violations of their civil rights and violation of civil laws such as the Computer Fraud and Abuse Act. The University of Michigan and Keffer Development Services were accused of gross negligence in their handling of student data. (link)
Mar 24: Title IX: The University of Maine System said Friday that it was found to be in compliance with federal and state laws, as well as NCAA rules that were changed following President Donald Trump’s executive order to prohibit transgender women and girls from competing in female sports. The confirmation came after the Trump administration had previously said an investigation had found Maine’s Department of Education violated Title IX, which bans sex-based discrimination in educational programs that receive federal funding, and that the Department of Agriculture would be suspending federal funds to the University of Maine System while it investigated potential Title IX violations. (link)
Mar 21: Title VI: Columbia University agreed Friday to put its Middle East studies department under new supervision and overhaul its rules for protests and student discipline, acquiescing to an extraordinary ultimatum by the Trump administration to implement those and other changes or risk losing billions of dollars in federal funding. As part of the sweeping reforms, the university will also adopt a new definition of antisemitism and expand "intellectual diversity" by staffing up its Institute for Israel and Jewish Studies, according to a letter published Friday by the interim president, Katrina Armstrong. Earlier this month, the Trump administration pulled $400 million in research grants and other funding over the university’s handling of protests against Israel’s military campaign in Gaza. (link)
Mar 19 : Title IX: The Trump administration has suspended approximately $175 million in federal funding for the University of Pennsylvania over a transgender swimmer who last competed for the school in 2022, the White House said Wednesday. President Donald Trump signed an executive order on Feb.5 that was intended to ban transgender athletes from competing in girls and women’s sports. The next day, the Education Department announced an investigation into Penn’s swimming program. But the Ivy League school’s federal money was suspended in a separate review of discretionary federal money going to universities, the White House said. Trump’s executive order on transgender athletes allows federal agencies to withhold funding if an entity does not follow the administration’s interpretation of Title IX, which outlaws sex-based discrimination in schools and colleges. (link)
Mar 19 : Research Compliance: Today, Chairman John Moolenaar of the House Select Committee on China sent a letter to the Presidents of Carnegie Mellon, Purdue University, Stanford University, the University of Illinois, the University of Maryland, and the University of Southern California requesting information on each of their policies and practices regarding the enrollment of Chinese national students in advanced STEM programs, questioning their involvement in federally funded research. The letter highlights the increasing risks posed by China’s strategic efforts to exploit American universities for technological and military advancements. Intelligence officials have warned that American campuses are soft targets for espionage and intellectual property theft, yet elite universities continue to admit large numbers of Chinese nationals into critical research programs prioritizing financial incentives over long-term national security and the education of American students in essential fields. (link)
Mar 14 : Title VI: The U.S. Department of Education’s Office for Civil Rights (OCR) opened investigations into 45 universities under Title VI following OCR’s February 14 Dear Colleague Letter (DCL) that reiterated schools’ civil rights obligations to end the use of racial preferences and stereotypes in education programs and activities. The investigations come amid allegations that these institutions have violated Title VI of the Civil Rights Act (1964) by partnering with "The Ph.D. Project," an organization that purports to provide doctoral students with insights into obtaining a Ph.D. and networking opportunities, but limits eligibility based on the race of participants. OCR is also investigating six universities for allegedly awarding impermissible race-based scholarships and one university for allegedly administering a program that segregates students on the basis of race. (link)
Mar 04 : State Law: Wyoming’s governor on Tuesday signed into law a bill banning government entities from favoring or disfavoring people by race, color, religion or sex, and from teaching those biases in schools or workplaces. At the same time, Gov. Mark Gordon vetoed a similar diversity, equity and inclusion (DEI) ban, saying the other bill wasn’t as clear or necessary. Sponsored by Rep. Rachel Rodriguez-Williams, House Bill 147 is now law. State governmental entities including the university and colleges have until July 1 to implement it. It defines "diversity, equity or inclusion" as programs, activities or policies that promote differential treatment of people by race, color, religion, sex, ethnicity or national origin. And it bans Wyoming and all its political entities from advancing DEI programs or requiring training in those themes. (link)
Mar 04: Federal Compliance: President Donald Trump said on Tuesday that all federal funding will stop for colleges and schools that allow "illegal" protests and that agitators will be imprisoned or sent back to the country they came from. "American students will be permanently expelled or, depending on the crime, arrested," Trump said in a Truth Social post. (link)
Mar 03: Regulatory Guidance: The Education Department late Friday unveiled a new document that appears to soften the agency’s stance on programs it could deem illegal after firing off a letter two weeks ago that threatened to pull federal funding from schools with diversity, equity and inclusion initiatives. The Education Department’s Office for Civil Rights Dear Colleague letter told Pre-K to higher education leaders it was illegal to consider race in all aspects of student, academic and campus life. The letter also gave them just two weeks to examine their programs that could face scrutiny. Friday’s question-and-answer document seems to be a little less sweeping than the initial guidance. (link)
Mar 01: Title IX: A former Liberty University staffer is suing the private Christian school, saying administrators fired him for reporting sexual harassment. Peter Brake worked as an investigator in the university’s Title IX office, typically the unit that investigates claims of sexual violence on campus. Among his claims, Brake, who was also an adjunct professor, alleges that his former boss harassed employees and was "prejudging cases." He also states he reported his concerns to his supervisors, including the university president. The lawsuit says he was fired because he "opposed discrimination and reported multiple violations of law to Liberty’s leadership and senior managers." (link)
Campus Life & Safety Events
Mar 20 : Free Speech: Northwestern denied tenure to Medill Prof. Steven Thrasher and plans not to renew his position in August 2026, Medill Dean Charles Whitaker informed Thrasher on March 12. In a Thursday news release, Thrasher accused Medill of targeting him for his participation in the April 2024 pro-Palestinian encampment, at which Thrasher formed a line between police and protesters. "This has nothing to do with my scholarship or teaching," Thrasher wrote in the news release. "It is a political hit job over my support for Palestine and for trying to protect our student protesters last year from physical attack, by nonviolently subjecting my own body to assault by the Northwestern Police." In January, the University found no grounds to suspend Thrasher based on the initial investigation and subsequently launched a new investigation into his conduct at the encampment, according to Thrasher. (link)
Mar 19: Campus Climate: A Georgetown University researcher, who was studying and teaching on a student visa, has been detained by federal immigration authorities amid the Trump administration’s crackdown on student activists whom the government accuses of opposing American foreign policy, according to court papers. Masked agents arrested Badar Khan Suri, an Indian national and postdoctoral fellow, outside his home in the Rosslyn neighborhood of Arlington, Virginia, on Monday night, his lawyer said in a lawsuit fighting for his immediate release. The agents identified themselves as being with the Department of Homeland Security and told him the government had revoked his visa, the lawsuit says. (link)
Mar 19: Vandalism: A 29-year-old University of Tennessee student was taken into custody Tuesday afternoon after authorities said she slashed the tires of dozens of cars on campus and in surrounding areas of Knoxville. The University of Tennessee Police Department identified her and said she was charged with vandalism, as well as drug charges and illegally having a gun. It said she was found within an hour of the first vandalism. She told police that she had not taken her medication for mental health, which led to a period where she blacked out. The Knoxville Police Department and UTPD said they collected 48 reports of vandalism. Most of the tires that were slashed can not be repaired, according to Scott Lacy, a tow truck driver. Instead, drivers will need to buy new ones. Cars with at least two slashed tires had to be towed. (link)
Mar 13 : Campus Protests: Columbia University has expelled or suspended some students who took over a campus building during pro-Palestinian protests last spring and temporarily revoked the diplomas of others who have since graduated, officials said Thursday. The university said in a campus-wide email that a judicial board brought a range of sanctions against students who occupied Hamilton Hall last spring to protest the war in Gaza. Columbia did not provide a breakdown of how many students were expelled, were suspended or had their degrees revoked, but it said the outcomes were based on an "evaluation of the severity of behaviors." The culmination of the monthslong investigative process comes as the university is reeling from the arrest of a well-known Palestinian campus activist, Mahmoud Khalil, by federal immigration authorities last Saturday. (link)
Mar 12: Campus Climate: Helyeh Doutaghi, a scholar in international law, began a new job in 2023 as the deputy director of a project at Yale Law School. As an activist who had championed pro-Palestinian causes in both published papers and public appearances, Dr. Doutaghi seemed to fit into the left-leaning mission of the Law and Political Economy Project, which promoted itself as working for "economic, racial and gender equality." Last week, though, she was abruptly barred from Yale’s campus in New Haven, Conn., and placed on administrative leave. She was told not to advertise her affiliation with the university, where she had also served as an associate research scholar. Yale officials cited the reason as allegations that she was tied to entities subject to U.S. sanctions. (link)
Mar 11 : Free Speech: In 2019, the Nevada System of Higher Education decided that students who needed remedial math instruction could receive it at the same time they were taking college-level math courses instead of completing it as a prerequisite. Those changes did not sit well with math professor Lars Jensen, who criticized them in two emails to TMCC faculty members and in a handout he distributed at a January 2020 "Math Summit" where "the community" was invited to discuss the curriculum revision. Because of that criticism, Jensen complained in a federal lawsuit, he received a letter of reprimand and two "unsatisfactory" performance reviews, which triggered a termination hearing. Those disciplinary actions, he argued, violated his First Amendment rights by punishing him for constitutionally protected speech. Although a federal judge dismissed Jensen's lawsuit with prejudice in September 2023, the U.S. Court of Appeals for the 9th Circuit revived his claims on Monday, ruling that the alleged conduct of TMMC administrators violated "clearly established" law, meaning they were not shielded by qualified immunity. (link)
Mar 11: Hazing: Three students are facing charges in connection to the alleged hazing death of Southern University and A&M College student Caleb Wilson, police announced Friday. [The three] are all Southern University and A&M College students, a spokesperson for the university confirmed to USA TODAY Tuesday afternoon. Wilson was rushed to the hospital last month after collapsing during an off-campus incident while pledging to the Omega Psi Phi fraternity. He was later pronounced dead at the hospital. "Wilson died as the direct result of a hazing incident where he was punched in the chest multiple times while pledging to (the) Omega Psi Phi fraternity," [Baton Rouge Chief of Police] Morse said Friday. (link)
Mar 09 : Campus Protests: Federal immigration authorities arrested a Palestinian activist Saturday who played a prominent role in Columbia University’s protests against Israel, a significant escalation in the Trump administration’s pledge to detain and deport student activists. Mahmoud Khalil, a graduate student at Columbia until this past December, was inside his university-owned apartment Saturday night when several Immigration and Customs Enforcement agents entered and took him into custody, his attorney, Amy Greer, told The Associated Press. Khalil’s arrest is the first publicly known deportation effort under Trump’s promised crackdown on students who joined protests against the war in Gaza that swept college campuses last spring. The administration has claimed participants forfeited their rights to remain in the country by supporting Hamas. (link)
Mar 06: Free Speech: A student LGBTQ+ organization is suing Texas A&M University over its newly adopted policy banning drag performances on its public campuses. The federal lawsuit was filed Tuesday on behalf of the Queer Empowerment Council, a coalition of student groups at Texas A&M University-College Station. The lawsuit aims to block the university from enforcing the policy, which the school's Board of Regents unanimously approved last week. The ban halts all drag performances on A&M's 11 public campuses, including the annual "Draggieland" event, which has been held on the College Station campus since 2020. (link)
Mar 05 : Campus Protests: About two dozen pro-Palestinian demonstrators at Barnard College in Manhattan occupied the lobby of the school’s main library on Wednesday, escalating a confrontation with school administrators and leading to several protesters being taken into custody, the police said. Chanting "Free Palestine" and wearing masks and kaffiyeh over their faces, the protesters began their sit-in inside the Milstein Center for Teaching and Learning about 1 p.m. The school blocked access to the building shortly afterward, and classes were disrupted. The protest came at a moment when pro-Palestinian activism on college campuses is a subject of intense interest to the Trump administration. In executive orders, President Trump has threatened to revoke federal funding to universities that allow what he and his administration regard as antisemitic activity, and he has made clear that pro-Palestinian protests, particularly those that appear to support Hamas, can qualify as such in his view. (link)
Mar 04: Assault: An 18-year-old was arrested and charged with first-degree rape on the University of Kentucky's campus, according to a criminal complaint. According to the complaint, UK Police responded just before 9:00 p.m. on Feb. 22 to "speak with the victim regarding a rape and strangulation that had occurred in a dorm on UK's campus on Feb. 18."Another individual has been arrested in connection to a Feb. 22 rape on the University of Kentucky's campus. An arrest complaint lists [an] 18-year-old [student] as a co-offender. [He] has been charged with first-degree rape and second-degree strangulation. (link)
Mar 01: Campus Climate: After receiving backlash about new bathroom signs, leaders at the University of Cincinnati are calling them a mistake. The university put signs up in some campus areas which read "biological men" and "biological women." They did this to comply with a new Ohio law requiring all school restrooms be designated for biological men and women. In response, students placed their own bathroom signs over top which simply said "bathroom." On Wednesday, school leaders sent an email to students and staff calling the signs an error and saying they'd be replaced. (link)
Mar 01 : Campus Protests: A Pro-Palestinian protest unfolded Wednesday at Barnard College in New York City, where a small group "forcibly entered" a campus hall and are alleged to have physically assaulted a school employee, college officials said. A sit-in demonstration was organized Wednesday at Barnard's Office of the Deans to protest the expulsion of two Barnard students last week over allegations of "disrupting" a Columbia University class on Israeli history a month earlier, according to the protest group Columbia University Apartheid Divest. Barnard College is an independent women’s college affiliated with Columbia in which students can take courses at both schools. During the protest, a small group of masked demonstrators "forcibly entered Milbank Hall" and "physically assaulted a Barnard employee, sending them to the hospital," Robin Levine, Barnard’s vice president for strategic communications, said in a statement Wednesday evening. (link)
If you have any suggestions, questions or feedback, please e-mail Kevin Robinson at robinmk@auburn.edu or Robert Gottesman at gotterw@auburn.edu. We hope you find this information useful and would appreciate hearing your thoughts. Feel free to forward this email to your direct reports, colleagues, employees or others who might find it of value. Back issues of this newsletter and subscription information are available on our website.