DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

On March 2, Deputy Attorney General Lisa Monaco announced the launch of a significant pilot program on compensation incentives and clawbacks during a speech at the ABA White Collar Crime Conference in Miami. Under the “first-ever” three-year pilot program, companies will be able to reduce criminal fines by attempting in good faith to claw back compensation from individual wrongdoers—even if those efforts are unsuccessful—and the companies will be able to retain any recovered funds. READ MORE