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- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By Adrianne Appel2023-03-16T13:58:00
Businesses and compliance professionals should expect the Department of Justice’s (DOJ) new compensation clawback policies to be applied on a case-by-case basis, with broad discretion, according to legal experts.
The clawback pilot program, announced March 2 by Deputy Attorney General Lisa Monaco, is part of a series of recent policy changes by the DOJ aimed at incentivizing companies to stay on the right side of ethics and the law. The agency also announced revisions to its Evaluation of Corporate Compliance Programs guidance regarding off-channel communications and new criteria for selecting compliance monitors in criminal cases.
The clawback pilot, launched Wednesday, will last three years and consists of two primary parts. First, companies are expected to link employee bonuses to compliance metrics. Second, businesses that get into trouble with the DOJ can earn a fine reduction, in whole or in part, if they seek to claw back compensation from corporate wrongdoers. If a company is successful and claws back the money, any potential fine could be reduced by the entire amount.
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2023-10-05T18:50:00Z By Kyle Brasseur
The Department of Justice’s push to incentivize companies to voluntarily self-disclose potential misconduct reached its next stage in the form of a safe harbor policy regarding mergers and acquisitions.
2023-06-21T14:06:00Z By Kyle Brasseur
Tool manufacturer Stanley Black & Decker avoided a civil penalty in settling with the Securities and Exchange Commission regarding alleged violations of executive perk disclosure rules.
2023-03-23T20:20:00Z By Kyle Brasseur
Compliance officers seeking clarity on what the Department of Justice means by “extraordinary” cooperation or “immediate” self-disclosure should look to the agency’s case history, said Assistant Attorney General Kenneth Polite Jr. during a speech.
2024-07-24T15:50:00Z By Aaron Nicodemus
Financial institutions holding Russian sovereign assets that have not reported them to the Treasury Department’s Office of Foreign Assets Control are now required to do so by Aug. 2.
2024-07-23T12:29:00Z By Ruth Prickett
Compliance officers should take note of proposed laws in the U.K. with the newly elected Labor government setting the legislative agenda in the King’s Speech last week, promising consultations on enhanced employee rights and a higher minimum wage.
2024-07-22T15:50:00Z By Aaron Nicodemus
Four federal banking regulators have joined the Treasury Department’s Financial Crimes Enforcement Network in issuing a notice of proposed rulemaking that would require financial institutions to conduct more thorough risk assessments on their anti-money laundering/countering the financing of terrorism programs.
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