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The Responsible Corporate Officer Doctrine

    https://www.skadden.com/-/media/files/publications/2018/12/theresponsiblecorporateofficerdoctrineprotectionsa.pdf
    May 10, 2007 · he responsible corporate officer (RCO) doctrine— which allows for criminal prosecution and impris-onment of an individual who was not personally involved in or aware of corporate misconduct—has been the subject of heated discussion in light of Food and Drug Administration (FDA) and Department of Justice (DOJ) of-

The “Responsible Corporate Officer Doctrine” Survives to ...

    https://corpgov.law.harvard.edu/2017/07/05/the-responsible-corporate-officer-doctrine-survives-to-perplex-corporate-boards/
    Jul 05, 2017 · The RCOD is a controversial strict liability theory interpreted by the government as permitting (in certain circumstances) the prosecution of corporate officers and directors for misdemeanor criminal offenses—without the need to establish their intent or personal involvement in wrongful conduct.

Synthes, the FDA and the responsible corporate officer ...

    https://medcitynews.com/2011/11/synthes-and-the-responsible-corporate-officer-doctrine/
    Nov 23, 2011 · The responsible corporate officer doctrine is a legal tool in the FDA’s armory that it has expressed the desire to use more frequently and has been used in some high-profile pharmaceutical ...

THE REVIVAL OF THE RESPONSIBLE CORPORATE OFFICER …

    https://www.goodwinlaw.com/~/media/Files/Publications/Attorney%20Articles/2013/Revival%20of%20the%20RCO%20Doctrine_Savage%20Klawiter.pdf
    rea, the FDA advised: The Park Doctrine…provides that a responsible corporate official can be held liable for a first time mis-demeanor…under the [FDCA] without proof that the corporate offi-cial acted with intent or even negligence, and even if such corpo-rate official did not have any actual knowledge of, or participation in, the

The New Era of Responsible Corporate Officer Doctrine ...

    http://www.rmmagazine.com/2012/08/29/the-new-era-of-responsible-corporate-officer-doctrine-enforcement/
    Aug 29, 2012 · Dating from a 1943 Supreme Court case, the responsible corporate officer (RCO) doctrine is being used to impose strict criminal liability on managers for corporate misconduct carried out on their watch, regardless of their prior knowledge or individual intent.

Trends In Responsible Corporate Officer Doctrine Under ...

    https://www.law360.com/articles/737403/trends-in-responsible-corporate-officer-doctrine-under-fdca
    Dec 14, 2015 · In recent years, the use of the responsible corporate officer (RCO) doctrine in federal prosecutions for violations of the Federal Food, Drug and Cosmetic Act (FDCA) has resurfaced, and prosecutors...

FDA’s use of the Park Doctrine against supplement ...

    https://www.naturalproductsinsider.com/legal-compliance/if-its-adulterated-you-may-be-incarcerated-criminal-liability-fdc-violations
    Jan 10, 2020 · Feb 01, 2021. U.S. v. Park (421 U.S. 658 [1975]) has become an increasingly utilized weapon in FDA’s enforcement arsenal throughout the last decade. The landmark case (commonly referred to as the “Park Doctrine” or “Responsible Corporate Officer” doctrine) reaffirms the Court’s decision in U.S. v. Dotterweich and imposes strict liability on corporate officials for misdemeanor violations of the Federal Food, Drug, and Cosmetic Act …

The Park Doctrine and FDCA Violations: Holding Corporate ...

    https://www.policymed.com/2011/11/the-park-doctrine-and-fdca-violations-holding-corporate-executives-accountable.html
    Nov 29, 2011 · The article then explained the “responsible corporate officer (RCO) doctrine,” established by United States v. Dotterweich and Park (reaffirming Dotterweich ), which provides “that a corporate agent who stands in a ‘responsible relation’ to misconduct may be held criminally liable even without having played any direct role in the misconduct.

CEO Sentenced to Six Months in Prison After Park Doctrine ...

    https://www.ropesgray.com/en/newsroom/alerts/2020/10/CEO-Sentenced-to-Six-Months-in-Prison-After-Park-Doctrine-Plea
    Oct 28, 2020 · The Indivior individual prosecutions raise the question of whether the government will begin pursuing responsible corporate officer charges against executives in FDA-regulated industries more often, or whether the responsible corporate officer language in the Thaxter plea documents simply reflects the result of a negotiated settlement of a case where the non-public investigational record may …

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