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Expert Analysis

Return Of Exec Accountability Creates Compliance Challenges

Law360, New York (August 10, 2016, 11:13 AM EDT) -- The continued willingness of federal courts to apply the harsh responsible corporate officer doctrine (RCOD) presents particular compliance — and executive retention — challenges for boards of certain types of life sciences and health care companies. A recent decision of the Eighth Circuit, upholding prison sentences for executives held to have committed misdemeanor violations of federal food and drug laws, confirms the continued viability of this enforcement theory as part of the government's enhanced efforts to hold individuals responsible for corporate wrongdoing....

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