Edward Imperatore spoke to Compliance Week about the Department of Justice’s (DOJ) new compensation clawback pilot program, which is part of a series of recent policy changes aimed at incentivizing companies to stay on the right side of ethics and the law.
According to Edward, the agency’s decision to issue a pilot program rather than a codified policy “suggests it’s going to be a work in progress.”
“This clawback policy is very general, includes vague terminology, and gives a lot of discretion to the DOJ as to how it will apply to a corporate resolution,” he said, noting that the pilot mentions businesses rewarding employees who demonstrate their “full commitment” to compliance processes, though it’s unclear how the DOJ would measure “full commitment.”
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