The Responsible Corporate Officer Doctrine: Protections are Needed Despite DOJ's Cautious Approach

Food and Drug Law Institute's Update

John T. Bentivoglio Jennifer L. Bragg Maya P. Florence Sydney P. Sgambato

Partners John Bentivoglio, Jennifer Bragg and Maya Florence and associate Sydney Sgambato review the responsible corporate officer doctrine, which allows for criminal prosecution and imprisonment of an individual who was not personally involved in or aware of corporate misconduct. Although prosecutors have limited enforcement actions largely to individuals with alleged knowledge of or involvement in such misconduct, the risk of enforcement overreach remains.

Posted with the permission of FDLI.

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