News & Analysis as of

Pilot Programs Clawbacks Compliance

NAVEX

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

NAVEX on

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

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

American Conference Institute (ACI)

Addressing the Jurisdictional Challenges of Compensation Clawbacks

The Department of Justice’s newly launched compensation and clawback pilot program is certain to bring with it numerous implementation hurdles and jurisdictional challenges, but it also incentivizes companies to have in place...more

BakerHostetler

New DOJ Policies Tie Employee Compensation to Compliance

BakerHostetler on

On March 15, 2023, the U.S. Department of Justice (DOJ or the Department) launched a three-year Compensation Incentives and Clawbacks Pilot Program (Clawback Program) intended to incentivize companies to create more robust...more

Perkins Coie

DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs

Perkins Coie on

The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more

Sheppard Mullin Richter & Hampton LLP

DOJ Revises Guidance on Evaluation of Corporate Compliance Programs Concerning Compensation and Employee Use of Personal Devices...

Following remarks made on March 2 and March 3, 2023 at the American Bar Association’s 38th Annual National Institute on White Collar Crime, the U.S. Department of Justice (“DOJ”) issued revisions to its Evaluation of...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

McDermott Will & Emery on

During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

Hogan Lovells

DOJ announces new polices concerning third party messaging apps and compensation clawbacks

Hogan Lovells on

This month, the Department of Justice (DOJ) announced various policy changes meant to promote corporate compliance and update DOJ’s “Evaluation of Corporate Compliance Programs.” This article discusses two of these policy...more

Morrison & Foerster LLP

DOJ’s Pilot Program Regarding Compensation Incentives and Clawbacks

On March 3, 2023, Kenneth A. Polite, Jr., the Assistant Attorney General (“AAG”) of the Criminal Division of the U.S. Department of Justice (“DOJ”), announced the launch of the Division’s Pilot Program on Compensation...more

Holland & Knight LLP

DOJ Announces Significant Policy Changes Affecting Corporate Criminal Enforcement

Holland & Knight LLP on

In back-to-back speeches to the American Bar Association's National Institute on White Collar Crime on March 2-3, 2023, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco and Assistant Attorney General...more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Ballard Spahr LLP

DOJ Announces New Policies on Clawbacks and Business-Related Communications

Ballard Spahr LLP on

Summary - Top U.S. Department of Justice officials announced the DOJ’s first-ever pilot program on corporate compensation incentives and clawbacks, as well as new policies on preservation of corporate communications, at...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

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