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https://www.cadwalader.com/resources/clients-friends-memos/the-responsible-corporate-officer-doctrine-in-the-wake-of-decoster#:~:text=The%20Responsible%20Corporate%20Officer%20Doctrine%20in%20the%20Wake,Confidential%20Reporting%20and%20Investigation.%20...%20More%20items...%20
https://www.wnj.com/publications/the-responsible-corporate-officer-doctrine-findi
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.
https://agilityportal.io/blog/park-doctrine-fda-the-responsible-corporate-officer-doctrine
There are two factors that are needed to be proven in order to apply the doctrine of the "Responsible Corporate Officer": (1) a corporate officer's authority to "prevent [the complaint] or swiftly make appropriate corrections in it" and (2) their failure to do so. Even without awareness, the officer's power is sufficient.
https://www.fdli.org/2018/11/the-responsible-corporate-officer-doctrine-protections-are-needed-despite-dojs-cautious-approach/
https://www.kelleydrye.com/News-Events/Publications/Articles/Responsible-Corporate-Officer-Doctrine-Strict-Cr
The Responsible Corporate Officer Doctrine makes certain regulatory crimes essentially strict liability offenses for corporate officers by not requiring a mens rea, or criminal intent, element as part of the offense.
https://corpgov.law.harvard.edu/2017/07/05/the-responsible-corporate-officer-doctrine-survives-to-perplex-corporate-boards/
https://www.compliance.com/resources/the-new-oig-responsible-corporate-officer-doctrine/
In his keynote address at the Annual Compliance Institute of the Health Care Compliance Association (“HCCA”), the Inspector General highlighted the responsible corporate officer doctrine, and proclaimed that “the OIG is focused on holding responsible corporate officials accountable for health care fraud.” [17]
https://www.quimbee.com/keyterms/responsible-corporate-officer-doctrine
Responsible-Corporate-Officer Doctrine Definition Also known as the Park doctrine, a strict-liability theory that permits corporate officers to be prosecuted for misdemeanor criminal offenses without having to establish their intent or that they were directly involved in the wrongful conduct.
https://www.dandodiary.com/2010/03/articles/corporate-governance/more-about-the-responsible-corporate-officer-doctrine/
The responsible corporate officer doctrine was first articulated by the U.S. Supreme Court in the 1943 case of United States v. Dotterweich, in which corporate officers in positions of authority were held personally (and in that case, criminally liable) for violating strict liability statutes protecting the public welfare.
https://www.skadden.com/-/media/files/publications/2018/12/theresponsiblecorporateofficerdoctrineprotectionsa.pdf
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 …
https://www.oklahoman.com/story/business/local/2014/08/17/what-you-need-to-know-about-the-responsible-corporate-officer-doctrine/60805392007/
The responsible corporate officer doctrine imposes strict liability on corporate officers based solely on their area of responsibility within the corporation, regardless of their knowledge of the underlying criminal activity or their participation in it.
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