DOJ Imposes New Standards for Evaluation of Corporate Compliance Programs: Compensations Structures that Promote Compliance (Part II of IV)
The Monaco Memo is a watershed moment as part of DOJ’s evolution and advocacy for effective ethics and compliance programs. We have seen prior moments of significant action — DOJ’s adoption of the FCPA Guidance, DOJ’s issuance of its Evaluation of Corporate Compliance Programs, and now the Monaco Memo which takes compliance into a new world with new opportunities and challenges. The Monaco Memo starts...