The U.S. Department of Justice’s recently implemented compensation incentives and clawbacks pilot program – under which penalties in enforcement actions may be reduced for companies that have policies to “clawback” monies from wrongdoers – has prompted HR, Legal, Compliance, and Corporate departments to consider potential modifications to their policies, to bring them in line with the pilot program’s provisions.
In this Law360 article, Partner Yogesh Bahl and Director Jonathan Hecht provide some guidance in this increasingly important area, examining the strategic, HR, and economic considerations that companies should take into account when designing and executing a clawback program. Read the full article here.