Tagged: compliance compensation system

Episode 284 — How to Implement a Compliance Compensation System

The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical underpinning of DOJ’s expanded focus is to increase the consequences to individuals who engage in misconduct or supervisors who turn a blind eye to misconduct.  Individuals already face potential criminal prosecution for engaging in misconduct but the...

How to Build a Compliance Compensation System (Part I of II)

The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical underpinning of DOJ’s expanded focus is to increase the consequences to individuals who engage in misconduct or supervisors who turn a blind eye to misconduct.  Individuals already face potential criminal prosecution for engaging in misconduct but the...

DOJ Announces New Requirements for Compliance Compensation Systems and Business Data Preservation (Part II of II)

The Justice Department promised that it would flesh out compliance program incentives requirements and preservation of business data as part of its revision of its Corporate Enforcement Policy.  In a pair of important speeches, DOJ officials, Deputy Attorney General Lisa Monaco, and Criminal Division Assistant Attorney General Kenneth Polite, previewed the new policies. Shortly after the speeches, the Justice Department released a new version of...