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The Responsible Corporate Officer Doctrine

    https://www.skadden.com/-/media/files/publications/2018/12/theresponsiblecorporateofficerdoctrineprotectionsa.pdf
    May 10, 2007 · he responsible corporate officer (RCO) doctrine— which allows for criminal prosecution and impris- onment of an individual who was not personally involved in or aware of corporate misconduct—has been the subject of heated discussion in light of Food and Drug Administration (FDA) and Department of Justice (DOJ) of- ficials’ threats of impending RCO prosecutions.

The Responsible Corporate Officer Doctrine: Finding ...

    https://www.wnj.com/publications/the-responsible-corporate-officer-doctrine-findi
    Aug 16, 2011 · Under the responsible corporate officer (RCO) doctrine, individual corporate officers can be found guilty of violating a variety of federal laws, such as the Federal Food, Drug and Cosmetic Act (FDCA), without exhibiting any unlawful intent, negligence, knowledge of the violation or direct participation in the wrongdoing.

Criminal Liability Under the Responsible Corporate Officer ...

    https://jenner.com/system/assets/publications/11455/original/Spacapan_IDQ.pdf?1358977
    Criminal Liability Under the Responsible Corporate Officer Doctrine Today’s pharmaceutical and device companies function in a world of complex and changing statutes and regulations. Robust and independent compliance programs are essential. Even with the best programs in place, however, rogues within the com-pany can expose the entire operation to

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