31 Days to a More Effective Compliance Program: Day 7 – Argentieri on Clawbacks and Holdbacks

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this episode, we explore the critical insights from the DOJ Clawback Program for compliance professionals. It emphasizes integrating compliance into the compensation structure as an effective strategy to promote ethical behavior and prevent misconduct. We also delve into the significance of financial accountability, noting the DOJ’s practice of reducing fines for firms that reclaim compensation from responsible employees. Finally, the episode highlights the necessity of continuously evaluating and enhancing compliance-linked compensation systems, urging companies to regularly assess their effectiveness, gather feedback, and make necessary adjustments. This iterative process reinforces the idea that compliance programs must be dynamic and proactive rather than static operational checklists.

Key highlights:

  • Integrating Compliance into Compensation
  • Financial Accountability Emphasis
  • DOJ’s Commitment to Individual Accountability
  • Continuous Evaluation and Improvement

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

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