by Claire A. Hill

Goldman Sachs recently admitted that it conspired to violate the Foreign Corrupt Practices Act’s (FCPA’s) anti-bribery provisions.  It agreed to pay a significant monetary fine and to enter into a deferred prosecution agreement.  These sorts of resolutions are common when companies are charged with violating the law.  But Goldman did something that is not common: it clawed back or reduced compensation for senior executives not directly involved in the wrongdoing.  It clawed back some amounts paid to senior executives during the time the misconduct was occurring, and it reduced 2020 compensation of present top management. Continue reading →