Earlier this month the SEC proposed new compensation clawback rules that would force executives to pay back performance-based bonuses if a financial restatement showed that they hadn’t really been earned. This might seem like a no-brainer (since the bonus was paid on performance that didn’t really take place), but the proposal only passed three to two and of course no one is eager to hand money back, earned or not. But US executives got off easy when you compare the SEC proposal to the UK rules that were recently finalized and will be in full effect at the beginning of…