March 10, 2023

Introducing the Government and Regulatory Rundown – March 2023

Michael Considine, Casey Jennings, Russell Johnston, Philip Moustakis, Jaimie Nawaday, Michael Watling

Seward & Kissel LLP

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DOJ Promotes Compliance Through Compensation and Clawback Programs (3.2.2023):

• The DOJ announced corporate criminal resolutions will now include a requirement that companies implement a compensation and bonus scheme that promotes compliance and rewards corporations that attempt to claw back payments to corporate wrongdoers.

• As part of a pilot program, the DOJ will reduce fines for companies that claw back compensation and companies will keep the recovered funds.

• Noting the difficulty of recouping payments, the DOJ stated that it will discount fines for corporations that make a good faith effort to claw back compensation but are ultimately unsuccessful.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.