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“Clawback Comeback”: DOJ’s New Focus on Clawbacks to Prevent Corporate Crime

Proskauer's Employee Benefits & Executive Compensa

In September 2022, Deputy Attorney General Lisa Monaco delivered remarks unveiling the Department of Justice’s revised corporate crime guidance to “prioritize and prosecute corporate crime.” To that end, Monaco emphasized that the DOJ will “reward” companies that claw back compensation from executives “when misconduct occurs.”