Once a CIA has been executed it is much easier for the government to reopen a case than to pursue a new one, and this ease of further prosecution, combined with increased OIG scrutiny and the threat of crippling penalties, substantially affects board knowledge, monitoring, and management.
Source quote, verbatim
Once a CIA has been executed, it is much easier for the government to reopen a case than to pursue a new one.
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Wulf A. Kaal, Elizabeth R. Malay, The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties (2013), III.2 Characteristics, p. 11 https://ssrn.com/abstract=2317580 · source PDF
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Wulf A. Kaal, Elizabeth R. Malay, The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties (2013). SSRN: https://ssrn.com/abstract=2317580
restateskaal:claim:2273857-064 Corporate integrity agreements improve corporate governance because the ease of reopened prosecution, increase...
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