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...