How Deputy AG’s Focus on Clawbacks and National Security Impacts Enforcement and Companies’ Compliance Efforts

Deputy Attorney General Lisa Monaco recently highlighted the DOJ Criminal Division’s pilot program regarding compensation incentives and clawbacks, unveiled in March. Promising more lenient penalties, the DOJ’s clawback policy encourages companies to reclaim monies paid to executives if they turned out to have been involved in FCPA violations. In her comments, Monaco also emphasized the DOJ’s focus on national security as a consideration for corporations. With insights from Miller & Chevalier, Cadwalader, Davis Polk and General Electric, this article distills Monaco’s remarks and what they mean for companies’ compliance efforts. See “Safe Harbor Policy Seeks to Encourage Self-Reporting of Issues in M&A Transactions” (Oct. 11, 2023). 

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