On March 3, 2023 the Department of Justice (“DOJ”) announced its Compensation Incentives and Clawbacks pilot program (the “Program”), which will become effective March 15, 2023..
Dept of Justice March 15, 2023 guidelines incl the preservation of business-related communications on employees phones computers, incl compliance related criteria into execs compensation bonus structures, fine reductions for corps if they seek to clawback compensation paid to executive wrongdoers