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The New OIG “Responsible Corporate Officer Doctrine”

    https://www.compliance.com/resources/the-new-oig-responsible-corporate-officer-doctrine/
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Tom Herrmann Discusses the New OIG “Responsible Corporate …

    https://www.compliance.com/resources/tom-herrmann-discusses-the-new-oig-responsible-corporate-officer-doctrine/
    In a recent article published in the Journal of Health Care Compliance, Thomas Herrmann provides his perspective on the new OIG “Responsible Corporate Officer Doctrine.” About the Author Thomas Herrmann advises health care clients on compliance and regulatory matters, with a focus on development and management of effective health care compliance programs.

The Responsible Corporate Officer Doctrine: Finding

    https://www.wnj.com/publications/the-responsible-corporate-officer-doctrine-findi
    The Responsible Corporate Officer Doctrine: Finding Executives Guilty of Crimes for What They Don’t Know. When most people think of criminal defendants, they envision a person who has intentionally broken the law. What many people don’t know, however, is that corporate officers can be subject to individual criminal prosecution in instances where they knew, or …

Responsible Corporate Officer: Not Just A Criminal Concept

    https://www.primerus.com/business-law-articles/responsible-corporate-officer-not-just-a-criminal-conscept-02212012.htm
    The responsible corporate officer doctrine established what amounts to strict liability for certain corporate officials and employees in criminal cases. The doctrine is now being used by many regulatory agencies, particularly those dealing with healthcare and pharmaceuticals, as a tool to debar employees and officials from the industry of which they have been a part for many years.

The Responsible Corporate Officer Doctrine: Protections …

    https://www.fdli.org/2018/11/the-responsible-corporate-officer-doctrine-protections-are-needed-despite-dojs-cautious-approach/
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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/
    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 Resurgence of the Responsible Corporate Officer …

    https://hawleytroxell.com/2012/06/the-resurgence-of-the-responsible-corporate-officer-doctrine/
    The Resurgence of the Responsible Corporate Officer Doctrine. Added by Hawley Troxell in Articles & Blogs, Health Law on June 14, 2012. Hospitals and healthcare systems and their attorneys should take note of the recent resurgence of the responsible corporate officer (RCO) doctrine. Aptly referred to as the crime of doing nothing, the RCO doctrine is a strict …

Responsible Corporate Officer Doctrine: When is Falling …

    https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2180098
    The FDA's recent deployment of the Responsible Corporate Officer Doctrine (also known as the Park Doctrine), and HHS OIG's presumption of federal health program debarment following an RCO Doctrine conviction has been extremely controversial.

The Responsible Corporate Officer Doctrine: Protections …

    https://www.skadden.com/insights/publications/2018/12/the-responsible-corporate-officer-doctrine
    December 2018 - January 2019. 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 …

The Responsible Corporate Officer Doctrine - Skadden

    https://www.skadden.com/-/media/files/publications/2018/12/theresponsiblecorporateofficerdoctrineprotectionsa.pdf
    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

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