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The Responsible Corporate Officer Doctrine

    https://www.skadden.com/-/media/files/publications/2018/12/theresponsiblecorporateofficerdoctrineprotectionsa.pdf
    May 10, 2007 · The Responsible Corporate Officer Doctrine: Protections are Needed Despite DOJ's Cautious Approach by John T. Bentivoglio, Jennifer L. Bragg, Maya P. Florence, and Sydney P. Sgambato T he responsible corporate officer (RCO) doctrine— which allows for criminal prosecution and impris-onment of an individual who was not personally

The Responsible Corporate Officer Doctrine: Finding ...

    https://www.wnj.com/publications/the-responsible-corporate-officer-doctrine-findi
    Aug 16, 2011 · Under the responsible corporate officer (RCO) doctrine, individual corporate officers can be found guilty of violating a variety of federal laws, such as the Federal Food, Drug and Cosmetic Act (FDCA), without exhibiting any unlawful intent, negligence, knowledge of the violation or direct participation in the wrongdoing.

The Responsible Corporate Officer Doctrine in the Wake of ...

    https://www.jdsupra.com/legalnews/the-responsible-corporate-officer-20983/
    May 04, 2017 · The Responsible Corporate Officer doctrine (“RCO doctrine”), commonly referred to as the Park doctrine, permits the government to prosecute employees for corporate misconduct when they are in a...

The Responsible Corporate Officer Doctrine in the Wake of ...

    https://www.cadwalader.com/resources/clients-friends-memos/the-responsible-corporate-officer-doctrine-in-the-wake-of-decoster
    May 03, 2017 · The Responsible Corporate Officer doctrine (“RCO doctrine”), commonly referred to as the Park doctrine, permits the government to prosecute employees for corporate misconduct when they are in a “position of authority” and fail to prevent or correct a violation of the Food, Drug and Cosmetic Act (“FDCA”). 1 Not only is it a strict liability offense, it is a vicarious liability …

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.

The New OIG “Responsible Corporate Officer Doctrine ...

    https://www.compliance.com/resources/the-new-oig-responsible-corporate-officer-doctrine/
    In his keynote address at the Annual Compliance Institute of the Health Care Compliance Association (“HCCA”), the Inspector General highlighted the responsible corporate officer doctrine, and proclaimed that “the OIG is focused on holding responsible corporate officials accountable for health care fraud.”

Criminal Liability Under the Responsible Corporate Officer ...

    https://jenner.com/system/assets/publications/11455/original/Spacapan_IDQ.pdf?1358977
    Criminal Liability Under the Responsible Corporate Officer Doctrine Today’s pharmaceutical and device companies function in a world of complex and changing statutes and regulations. Robust and independent compliance programs are essential. Even with the best programs in place, however, rogues within the com-pany can expose the entire operation to

More About the Responsible Corporate Officer Doctrine ...

    https://www.dandodiary.com/2010/03/articles/corporate-governance/more-about-the-responsible-corporate-officer-doctrine/
    Mar 08, 2010 · The responsible corporate officer doctrine was first articulated by the U.S. Supreme Court in the 1943 case of United States v. Dotterweich, in which corporate officers in positions of authority were held personally (and in that case, criminally liable) for violating strict …

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