- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2023-03-02T22:08:00
The Department of Justice (DOJ) might soon begin requiring companies seeking a settlement of criminal charges to claw back compensation from employees involved in the misconduct.
In remarks delivered Thursday, Deputy Attorney General Lisa Monaco said, “[E]very corporate resolution involving the Criminal Division will now include a requirement that the resolving company develop compliance-promoting criteria within its compensation and bonus system.”
Compliance-promoting criteria consists of two parts: demanding the return of compensation earned by employees engaged in misconduct (clawbacks) and implementing a corporate compensation and bonus program that would measure compensation tied to an employee’s compliance score. The DOJ is also establishing a pilot program to reduce a corporation’s fine by the amount of clawbacks demanded, Monaco said.
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