News & Analysis as of

Federal Pilot Programs Clawbacks

Foley Hoag LLP - White Collar Law &...

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 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

American Conference Institute (ACI)

Operationalizing the Revised ‘Evaluation of Corporate Compliance Programs’

While the U.S. Department of Justice’s Criminal Division published its fourth version of its “Evaluation of Corporate Compliance Programs (ECCP)” guidance more than six months ago now, the insights that in-house counsel and...more

The Volkov Law Group

Enforceability of Clawback and Compensation Penalty Provisions (Part II of II)

The Volkov Law Group on

We often read about lucrative bonus payments made to CEOs and other senior executives. With refinements in corporate governance structures, shareholders and investors are raising concerns over executive bonuses. To bring...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

The Volkov Law Group

DOJ’s Criminal Division Issues Three-Year Pilot Program for Corporate Compensation Systems and Clawbacks (Part II of III)

The Volkov Law Group on

The Justice Department is focusing with a laser beam on corporate incentives and disincentives.  This truly is a remarkable initiative and companies should undertake their own holistic review of internal incentives and...more

Jenner & Block

Client Alert: Key Insights from Updated DOJ Guidance Regarding the “Evaluation of Corporate Compliance Programs” and New...

Jenner & Block on

On Friday, March 3, 2023, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its fourth iteration, this guidance replaces the June...more

Kramer Levin Naftalis & Frankel LLP

DOJ Reinforces Its Focus on Affirmative Corporate Accountability at the ABA’s 38th Annual White Collar Conference

Earlier this month, at the American Bar Association’s (ABA) 38th National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite, Jr. highlighted the...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

Miles & Stockbridge P.C.

Individual Accountability Expanded: DOJ Launches Corporate Compliance Pilot Program Focused on Compensation System and Clawbacks

The U.S. Department of Justice (DOJ) announced Friday a three-year pilot program related to its continued efforts to hold individuals directly accountable for corporate wrongdoing. The two-pronged program incentivizes...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

Dorsey & Whitney LLP on

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

Morgan Lewis

DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

Morgan Lewis on

The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more

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