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Experts: DOJ Clawback Pilot to be ‘Work in Progress’, Compliance Week

Thursday, March 16, 2023

Partner John Pease spoke with Compliance Week regarding the US Department of Justice’s (DOJ’s) new compensation clawback policies.

The clawback pilot program—announced March 2, 2023 by Deputy Attorney General Lisa Monaco—is part of a series of recent policy changes by the DOJ to incentivize companies to stay on the right side of ethics and the law.

The agency also announced revisions to its Evaluation of Corporate Compliance Programs guidance regarding off-channel communications and new criteria for selecting compliance monitors in criminal cases.

“The expectation isn’t that the DOJ snaps its fingers and expects you to have a fully functional clawback program. But it is expecting you to start that process,” John said.

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