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

Proskauer's Employee Benefits & Executive Compensa

With this focus on executive compensation clawbacks, the DOJ is stepping into an area first highlighted by the Dodd-Frank Act of 2010, which directed the Securities and Exchange Commission to promulgate rules requiring publicly-listed companies to have compensation clawback policies.

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Long Time Coming: SEC Adopts Final Dodd-Frank Clawback Rules

Proskauer's Employee Benefits & Executive Compensa

Twelve years after the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and many years after the Securities and Exchange Commission started considering regulations implementing the clawback provisions of Dodd-Frank, the SEC published the Final “Clawback” Rules (the “Final Rules”) on October 26, 2022.

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Employee bonus programs that drive sales performance

Empuls

Sales commission Salespeople get extra money based on how much they sell. Sales commission also incentivizes salespeople to focus on achieving sales targets. For Example Oracle uses a sales commission structure to reward its salespeople based on the amount of revenue they generate.

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