Employers will not be able to take full advantage of the DOJ’s new program if their compensation systems do not permit clawbacks from wrongdoer employees. Companies should review their existing compensation systems and...more
The Department of Justice (“DOJ”) announced that it is stepping back from its hard-line approach to corporate cooperation credit in which a corporation was not eligible for credit unless it disclosed all relevant facts about...more
Action Item: On April 5, 2016, the U.S. Department of Justice (“DOJ”) issued a memorandum laying out a one-year pilot program designed to offer mitigation credit to companies that voluntarily disclose Foreign Corrupt...more