Tagged: DOJ payment compensation systems and compliance

Incentives and Disincentives as the New Engine of Effective Compliance (Part I of III)

Incentives and Disincentives as the New Engine of Effective Compliance (Part I of III)

Some were surprised by the recent move by the Department of Justice in focusing on the importance of incentives and disincentives as an important factor in an effective ethics and compliance program.  Others, however, had been waiting for years to this occur.  To these compliance professionals, DOJ was finally arriving, although late to the game. If we take a step back, the issue is nothing...