The Redmond, Wash.-based company had 30 days to create the committee, made up of three Microsoft board members. James Cash, a professor at Harvard Business School and chairman of Harvard Business School publishing, will chair the committee. Cash joined Microsoft's board in June 2001.

Raymond Gilmartin, chief executive of Merck & Co., and former U.S. Secretary of Labor Ann McLaughlin also will serve on the compliance committee. The committee's next task is to hire a compliance officer to act as a liaison between the three members and federal and state trustbusters.