News & Analysis as of

Compliance Department of Justice (DOJ) Incentive Compensation

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Thomas Fox - Compliance Evangelist

Categories Key Compliance Speeches from 2023-DAG Monaco on a Culture of Compliance

In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity.  The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General...more

Thomas Fox - Compliance Evangelist

Executive Compliance Comp and Compliance: From Incentives to Clawbacks

There are two problems that every company must deal with at the intersection of executive compensation and compliance. The first is the presence of perverse incentives within organizations, where executives are often...more

Williams Mullen

DOJ Implements Corporate Self-Disclosure Policy for Criminal Misconduct

Williams Mullen on

A new voluntary self-disclosure policy issued by the United States Department of Justice (DOJ) provides incentives for companies that voluntarily report criminal misconduct by their employees or agents....more

Orrick, Herrington & Sutcliffe LLP

In Like a Lion: DOJ Marks March with a Series of New Compliance Policies

DOJ is roaring into March with updates to its guidance on the evaluation of corporate compliance programs, a new pilot program on compensation incentives and clawbacks, and a revised policy on monitor selection, all released...more

Bradley Arant Boult Cummings LLP

Compensation Incentives and Clawback Provisions: DOJ Launches Pilot Program to Encourage Corporate Compliance Programs

On March 3, the Criminal Division of the Department of Justice announced a two-part pilot program to encourage corporations to implement compliance programs with provisions for employee compensation incentives and clawbacks...more

Hogan Lovells

You want what back? Key takeaways from DOJ on compensation clawbacks and compliance programs

Hogan Lovells on

On September 15, 2022, Deputy Attorney General Lisa Monaco released a memorandum titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group,” known...more

The Volkov Law Group

DOJ’s Perspective on Clawbacks and Deferred Compensation Systems (Part III of III)

The Volkov Law Group on

DOJ’s decision to examine corporate compensation programs as an important part of a compliance program should be welcomed.  DOJ’s initiative asks a very good question – how can incentives and disincentives be used to promote...more

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