Perspective
Oct. 13, 2016
Compliance programs even more essential after Jensen
After the decision endorsing disgorgement against executives whether or not their personal misconduct caused an accounting restatement, compliance programs designed to eliminate corporate "misconduct" are more essential than ever. By Scott M. Wornow
With a recent 9th U.S. Circuit Court of Appeals decision (SEC v. Jensen, 2016 DJDAR 9113 (Aug. 31, 2016)) endorsing a broad disgorgement remedy under the Sarbanes-Oxley Act against corporate executives whether or not their personal misconduct caused an accounting restatement, compliance programs designed to eliminate - or at least substantially diminish the likelihood of - corporate "misconduct" are more essential than ...
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