Tagged: compliance compensation

DOJ Begins Implementation of Compliance Compensation Requirements

The Justice Department has taken steps to implement its new compliance compensation requirement announced in its Corporate Enforcement Policy revisions.  With little fanfare, the Danske Bank $2 billion settlement with the Justice Department include an additional provision in its settlement papers outlining the new requirement. DOJ’s settlement papers include standard provisions that have grown through the years.  Schedule C has set forth DOJ requirements for...

Next Steps for CCOs – Revising Compensation Systems and Enhancing Data Preservation Technology

Just when we thought the ethics and compliance landscape was “stable,” the Justice Department pulled the compliance profession further and announced heightened expectations for corporate compliance programs.  For prognosticators like myself it is easy to predict that next year companies will have to focus on their compensations systems and data preservation capabilities. DOJ has promised to issue additional guidance on these two important issues.  However,...