A global shift in the regulatory approach to penalties is leading to greater fines across more geographies and using a wider variety of recourse against a bigger cross-section of targets, notably individuals and corporate executives. Not even annual bonuses, stock shares and promotions are safe under the broadening definitions of clawbacks being sought. A recent Women in White Collar Defense Association discussion featuring attorneys from the SEC, SFO, the U.S. Sentencing Commission, Dechert, Morrison & Foerster and Kobre & Kim reviewed approaches to asset forfeiture and how collaboration and creativity could lead to a reduction in misconduct. See “DOJ Is Evolving Its Focus and Encourages Companies to Join
” (May 11, 2022).