The “Responsible Corporate Officer Doctrine” Survives to Perplex Corporate Boards

Overview


Michael Peregrine wrote this bylined article on how the government’s Responsible Corporate Officer Doctrine (RCOD) “will remain a disconcerting compliance risk that boards in several key industries must monitor.” RCOD prosecutions have focused on pharmaceutical and medical device companies, which Mr. Peregrine wrote “presents unique cultural, compliance and executive retention challenges” to the boards of those companies.