We’ve recently been made aware of an increase in anonymous hoax emails and online reports posted to multiple companies through their internal reporting systems. The wording of these posts were identical and alleged violation...more
How should my compliance program prepare for the Trump administration? This is a question I have been asked a lot over the past few weeks. And as we start a new year and a second Trump administration that promises to be a...more
1/3/2025
/ Chief Compliance Officers ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Environmental Social & Governance (ESG) ,
Ethics ,
Regulatory Requirements ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Tariffs ,
Transparency ,
Trump Administration
Those of us in compliance and whistleblower programs have been eagerly awaiting the release of the SEC Office of the Whistleblower (OWB) report, and on November 21st, we were able to view the highly anticipated recap (dated...more
In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more
2/20/2024
/ Board of Directors ,
Bribery ,
C-Corporation ,
C-Suite Executives ,
Chief Compliance Officers ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Cybersecurity ,
Data Privacy ,
Department of Justice (DOJ) ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Human Rights ,
Popular ,
Regulatory Oversight ,
Risk Management ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
Whistleblowers
On November 14, 2023 the Securities and Exchange Commission (SEC) released its annual Office of the Whistleblower Report to Congress for fiscal year 2023 (October 1, 2022-September 30, 2023). This report highlighted several...more
11/21/2023
/ Accounting ,
Annual Reports ,
Audits ,
Compliance ,
Corporate Misconduct ,
Enforcement ,
Ethics ,
Financial Reporting ,
Internal Reporting ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
On November 15th, the Securities and Exchange Commission (SEC) Office of the Whistleblower (OWB) released its 2021 Annual Report to Congress that reports staggering statistics for FY 2021 and should sound warning bells for...more
In an expected ruling, the Supreme Court held that Dodd-Frank’s anti-retaliation provision does not extend to an individual who has not reported a violation of the securities laws to the SEC. The court signaled this outcome...more
2/23/2018
/ Anti-Retaliation Provisions ,
Digital Realty Trust Inc v Somers ,
Dodd-Frank ,
Internal Reporting ,
Reporting Requirements ,
Retaliation ,
Sarbanes-Oxley ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Whistleblower Protection Policies ,
Whistleblowers
The headlines lit up this month when the Securities and Exchange Commission (SEC) issued its first-ever award to a whistleblower who wasn’t employed by the company on which he had blown the whistle. The award was a...more
On November 16, 2015, the U.S. Securities and Exchange Commission issued its 2015 Annual Report to Congress on the Dodd-Frank Whistleblower Program and, to no one’s surprise, the program is going strong awarding over $37M to...more
Last November, the U.S. Securities and Exchange Commission issued its Annual Report to Congress on the Dodd-Frank Whistleblower Program. It is clear that the program is going strong. Following are five key ways compliance...more
1/23/2015
/ Best Practices ,
Chief Compliance Officers ,
Compliance ,
Dodd-Frank ,
Employer Liability Issues ,
Internal Reporting ,
Retaliation ,
Risk Assessment ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Whistleblower Protection Policies
On the accountability and punishment front, three trends bear watching:
1) Deferred Prosecution Agreements (DPAs)
DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more
1/21/2015
/ C-Suite Executives ,
Chief Compliance Officers ,
Compliance ,
Corporate Integrity Agreement ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Ethics ,
Non-Prosecution Agreements ,
Personal Liability ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Strategic Enforcement Plan ,
UK
On November 17, the U.S. Securities and Exchange Commission issued its 2014 Annual Report to Congress on the Dodd-Frank Whistleblower Program and it is clear that the program is going strong. Following are six key takeaways...more
11/20/2014
/ Annual Reports ,
Confidentiality Agreements ,
Dodd-Frank ,
Employer Liability Issues ,
Employment Contract ,
Enforcement Statistics ,
Internal Investigations ,
Popular ,
Restrictive Covenants ,
Retaliation ,
Securities and Exchange Commission (SEC) ,
Severance Agreements ,
Strategic Enforcement Plan ,
Whistleblowers
Last week, the SEC announced its first whistleblower award to an audit and compliance professional. The $300,000 award announcement noted that the recipient had “reported concerns to appropriate personnel within the company,...more