News & Analysis as of

Clawbacks Compliance Corporate Counsel

Foley Hoag LLP - White Collar Law &...

Anticorruption and FCPA Enforcement: Takeaways and Lessons Heading into 2025

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

Venable LLP

December 1 Deadline Nears for Adoption of Clawback Policies

Venable LLP on

Companies that are listed on the Nasdaq Stock Market or the New York Stock Exchange are required to adopt a clawback policy that provides for the recovery from any current or former executive officers of incentive-based...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Approves Stock Exchange Rules for Dodd-Frank Clawbacks

On June 9, 2023, the Securities and Exchange Commission (SEC) approved, on an accelerated basis, the New York Stock Exchange’s (NYSE) and Nasdaq Stock Market’s (Nasdaq) proposed listing standards implementing the SEC’s...more

Orrick, Herrington & Sutcliffe LLP

In Like a Lion: DOJ Marks March with a Series of New Compliance Policies

DOJ is roaring into March with updates to its guidance on the evaluation of corporate compliance programs, a new pilot program on compensation incentives and clawbacks, and a revised policy on monitor selection, all released...more

Ballard Spahr LLP

DOJ Announces New Policies on Clawbacks and Business-Related Communications

Ballard Spahr LLP on

Summary - Top U.S. Department of Justice officials announced the DOJ’s first-ever pilot program on corporate compensation incentives and clawbacks, as well as new policies on preservation of corporate communications, at...more

Orrick, Herrington & Sutcliffe LLP

U.S. Department of Justice Rolls Out New Policy to Incentivize Companies to Implement Executive Compensation Systems that...

During a March 2, 2023, speech in Miami at the annual American Bar Association National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy designed to incentivize companies to factor...more

Morgan Lewis

DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

Morgan Lewis on

The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more

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