"The Responsible Corporate Officer Doctrine: What You Don’t Know May Make You a Criminal"

In this article, Joel Levin and Chip Mulaney discuss the Responsible Corporate Officer Doctrine (also known as the Park doctrine) which provides that executives can be held criminally liable for certain offenses if they have the authority to correct or prevent the corporation’s unlawful conduct and fail to do so, even if they were unaware of the misconduct. It offers tips for executives to mitigate the risk of an RCOD enforcement, which has become an increasingly popular tool of the government, particularly in the pharmaceutical area.