News & Analysis as of

Clawbacks Compliance

Offit Kurman

Lenders Must Act Fast to Recover Funds in Fraudulent Loan Schemes

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Lenders get into a groove with originating loans with existing and new borrowers. So often, the closing comes and goes, and the monthly payments commence without any trouble. But then a borrower comes along who seeks to...more

Foley Hoag LLP - White Collar Law &...

Anticorruption and FCPA Enforcement: Takeaways and Lessons Heading into 2025

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

White & Case LLP

Key Considerations for the 2025 Annual Reporting and Proxy Season: Your Upcoming Form 10-K

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Each year in our Annual Memo, White & Case's Public Company Advisory Group provides practical insights on preparing Annual Reports on Form 10-Ks, Annual Meeting Proxy Statements and, for FPIs, the Annual Report on Form 20-F....more

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: Special Considerations for Publicly-Traded Companies

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This article is the seventh and final in our series on equity-based compensation. It will provide an overview of special considerations for publicly-traded companies when granting equity awards, including the impact of proxy...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Thomas Fox - Compliance Evangelist

2024 ECCP-Embracing Continuous Improvement

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute, Principal Deputy Assistant Attorney General Nicole M. Argentieri discussed the Evaluation of Corporate...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Thomas Fox - Compliance Evangelist

The Argentieri Speech: Mid-Point Reflections on the DOJ’s Compensation Clawback Pilot Program

Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. She reiterated the long-stated policy that compliance...more

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

Epiq

Compliance Programs Under Scrutiny

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In today’s regulatory environment, corporations have a heightened obligation to investigate potential wrongdoing by their employees and to monitor, and possibly disclose, incidents of illegal conduct....more

Health Care Compliance Association (HCCA)

Cleveland Clinic Pays $7.6M Related to PI Whose Charges Were Dropped; ‘He Was Treated Horribly’

Attorney Peter Zeidenberg was surprised to learn that NIH had successfully clawed back $3.6 million—plus a nearly 100% penalty—from Cleveland Clinic. The Department of Justice (DOJ) claimed the award funds were ill-gotten...more

King & Spalding

Effect of New FTC Rule Banning Post-Employment Non-Compete Agreements on Executive Compensation Arrangement

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On April 23, 2024, the Federal Trade Commission issued its final rule imposing a nationwide ban on employers using post-employment non-competes with current and former workers. Other than narrow exceptions for (1) existing...more

American Conference Institute (ACI)

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

NAVEX

How to Meet the Letter, Spirit and Intent of the DOJ’s Evolving Compliance Program Expectations

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With any new administration, the U.S. Department of Justice (DOJ) often shifts focus from one set of enforcement priorities to another. However, one area has remained a focus from administration to administration: guidance...more

Mintz

EnforceMintz — DOJ and OIG Guidance Emphasizes the Importance of a Robust and Dynamic Compliance Program

Mintz on

2023 was a busy year across several federal agencies in terms of issuing compliance guidance for corporations, including health care companies. For example, the Department of Justice (DOJ) issued significant compliance...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Sheppard Mullin Richter & Hampton LLP

2024 Top-of-Mind Issues for Life Sciences Companies

As we reflect on 2023 and make predictions for 2024, it is remarkable the number of significant events occurring this past year that will be impactful for the activities of the life sciences industry going forward. Although...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

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This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

Thomas Fox - Compliance Evangelist

Key Compliance Speeches from 2023 - Kenneth Polite on Incentives and Consequence Management

Assistant Attorney General Kenneth A. Polite, Jr. began his speech with an interesting aside. It is about the clear tie between poverty and corruption. This is why it is important to prosecute corrupt government officials...more

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

Snell & Wilmer

Corporate Communicator - 2024 Annual Meeting Season

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Clawback Rules. As previously discussed in last Winter’s Corporate Communicator, the Securities and Exchange Commission (“SEC") adopted final rules in October 2022 directing the NYSE and Nasdaq to adopt listing standards that...more

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