This Article examines the common law respondeat superior test for corporate criminal liability and proposes that it be expanded to include moral culpability. This Article supports this proposal by noting that the Department of Justice has already incorporated a moral culpability element into its analysis of corporate. criminal liability through the Department’s Principles of Federal Prosecution of Business Organizations. While some might argue that the Department of Justice’s voluntary implementation of a new corporate criminal liability standard is enough, this Article discusses two fundamental flaws with this position. First, while federal prosecutors’ consideration of the Principles of Prosecution may be “mandatory,” these guidelines create no legal rights for corporate defendants. Second, the Principles of Prosecution contain elements for consideration that are outside the appropriate scope of inquiry because they examine the corporation’s actions after the criminal conduct under scrutiny. Thus, this Article proposes a revised common law respondeat superior test that includes a legally binding moral culpability element that focuses on a refined and appropriately limited group of pre-offense and offense-specific factors: the nature and seriousness of the offense; the pervasiveness of wrongdoing within the corporation; the corporation’s history of similar conduct; and the existence and adequacy of the corporation’s preexisting compliance program.