Insights

Diana Lloyd and Meg Ziegler Published in The Bulletin on Compensation Clawbacks Program

Diana Lloyd, Co-Chair of Choate’s Government Enforcement and Compliance Group and Associate Meg Ziegler co-authored the article “Compensation Clawbacks: Domestic and International Considerations of DOJ Pilot Program,” published in The Bulletin of The International Academy of Financial Crime Litigators. Published in the inaugural issue of The Bulletin, the article takes a careful look at the Department of Justice’s three-year Pilot Program on compensation incentives and clawbacks, and its potential impact on companies.

In an effort to limit compensation-based corporate fraud in the United States and globally, the DOJ’s program aims to expand the burden of responsibility for corporate wrongdoing to include responsible individual employees and executives, in addition to a company and its shareholders. While questions remain about the scope and enforceability of the Program within each state or country’s labor and wage laws, the article highlights measures that companies can take to mitigate risk if faced with a government investigation.

The International Academy of Financial Crime Litigators is a collaborative organization of public- and private-sector litigation professionals focused on developing research and experience based solutions to cases of economic crime. For more information about the Academy and The Bulletin, please click here.