Tagged: Corporate compliance programs

DOJ’s Criminal Division Issues Three-Year Pilot Program for Corporate Compensation Systems and Clawbacks (Part II of III)

The Justice Department is focusing with a laser beam on corporate incentives and disincentives.  This truly is a remarkable initiative and companies should undertake their own holistic review of internal incentives and disincentives.  For years, we have heard about corporate incentives to achieve earnings and how sales rewards can unintentionally distort compliance.  As an important step, DOJ’s Criminal Division recently issued its new, three-year Pilot...

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

People disagreeing on all just about everything, yeah Makes you stop and all wonder why Why only yesterday I saw somebody on the street Who just couldn’t help but cry Oh, this ol’ river keeps on rollin’, though No matter what gets in the way and which way the wind does blow And as long as it does I’ll just sit here And watch the...