WebMar 14, 2024 · The U.S. Department of Justice (DOJ) recently announced a series of updates to its guidance related to corporate compliance programs, including revisions to the Evaluation of Corporate Compliance Programs (the 2024 Evaluation Guidance ), the Revised Memorandum on Selection of Monitors in Criminal Division Matters (the Monitor … WebApr 10, 2024 · First, DAG Monaco and AAG Polite announced DOJ’s first-ever Pilot Program on Compensation Incentives and Clawbacks (Pilot Program) requiring companies to “develop compliance-promoting criteria within its compensation and bonus systems.”. The new Pilot Program—as well as announcements relating to additional resource …
DOJ Updates Its Guidance on Corporate Compliance Programs
WebMar 3, 2024 · Our goal is to ensure that the company uses compliance-related criteria to reward ethical behavior and punish and deter misconduct. As to clawbacks: for companies that fully cooperate with our investigation and timely and appropriately remediate the misconduct, they may receive an additional fine reduction if the company has … WebApr 10, 2024 · First, DAG Monaco and AAG Polite announced DOJ’s first-ever Pilot Program on Compensation Incentives and Clawbacks (Pilot Program) requiring … light stain for oak flooring
Mauro Wolfe on LinkedIn: BREAKING: DOJ To Reward Clawbacks, …
WebSep 15, 2024 · According to Monaco and Assistant Attorney General Polite, the DOJ will also reward companies that pursue clawbacks in good faith but are unsuccessful with fine reductions. According to Polite, prosecutors will have discretion to reduce a resolving company’s fine by 25 percent in the event the company is unsuccessful in its good faith … WebMar 23, 2024 · AAG Polite emphasized that the DOJ expects companies to pursue clawbacks not only against the employees who engaged in wrongdoing but also against any supervisors who knew of the misconduct or ... WebSep 15, 2024 · Companies that amplify their compliance programs and seek to claw back compensation from culpable executives will be rewarded by the DOJ. As Monaco stated … light stain for pine ceiling