Thinking about Clawbacks

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include:

·       What are clawbacks?

·       What does the SEC rule require?

·       Are clawbacks the mirror of executive incentives?

·       How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements?

·       How far down the corporate chain must a clawback provision impact?

 Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

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