Clawing Back the DOJ’s Compensation Clawback Pilot Program

February 28, 2024

Martin Weinstein and Emily Wells co-authored an article, “Clawing Back the DOJ’s Compensation Clawback Pilot Program,” that appeared in the Anti-Corruption Report on February 28.

Martin and Emily discuss one of the most significant policy updates of 2023: the DOJ Criminal Division’s rollout of a pilot program relating to “Incentives and Compensation Clawback[s].” They go on to analyze whether the program’s Deferred Fine Reduction component, as currently drafted, can meet its aims to “reward corporations” and “shift the burden of corporate financial penalties away from shareholders.”

Read it here.