2 Gurus Talk Compliance: Episode 57 — The Tom on His Highhorse Edition
Daily Compliance News: August 6, 2025, The Spanking Banks Edition
FCPA Compliance Report: Navigating Corporate Scandals: Insights on Governance, Compliance, and Recovery with Steve Vincze
FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce
Data Driven Compliance: Understanding the UK’s New Failure to Prevent Fraud Offense with Sam Tate
Daily Compliance News: July 25, 2025, The New Sheriff in Town Edition
Daily Compliance News: July 23, 2025 the Pardon in the Wind? Edition
Daily Compliance News: July 21, 2025, The More Reasons Not to Go to China Edition
Daily Compliance News: July 16, 2025, The Corruption Comes to Cannes’ Edition
All Things Investigation: Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner
Daily Compliance News: July 10, 2025, The Loyalty Oath Edition
Compliance Tip of the Day: Lessons from Internal Control Failures
Daily Compliance News: July 7, 2025 the Disaster on the River Edition
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
The Dark Patterns Behind Corporate Scandals
Compliance into the Weeds: Boeing’s New Safety Initiatives and Compliance Reforms
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
Daily Compliance News: June 13, 2025. The All Boeing Edition
Adventures in Compliance: The Novels: The Sign of Four – Applying Sherlock Holmes’ Methods to Modern Corporate Compliance
2 Gurus Talk Compliance: Episode 53 – The AI as a Whistleblower Edition
On January 10, 2025, the SEC announced settled charges against Vince McMahon, former Executive Chair and CEO of World Wrestling Entertainment Inc., for signing two settlement agreements without disclosure to the board, anyone...more
The Sarbanes-Oxley Act of 2002, also referred to as SOX or as Sarbox, is a federal statute that requires specific corporate recordkeeping measures as well as financial reporting. It was passed in the aftermath of several huge...more
The U.S. Securities and Exchange Commission’s (SEC) Whistleblower Program was created in Section 922 of the Dodd-Frank Act of 2010, which amended the Securities Exchange Act to include a whistleblower provision. It has since...more
On March 1, 2024, the Second Circuit affirmed the judgment of the Southern District of New York in Brian La Belle v. Barclays Capital Inc, No. 23-448 (2d Cir. 2024)....more
In part one of this three-part blog series, we’re going back to the basics. In this article, we’ll answer the question: what is a whistleblowing hotline? A whistleblowing hotline is a channel that allows employees and others...more
The Sarbanes-Oxley Act (SOX) protects employees of public corporations who report alleged financial misconduct from retaliation by their employers. Last week, the Eleventh Circuit Court of Appeals concluded that an employee’s...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
On March 3, 2023, Kenneth A. Polite, Jr., the Assistant Attorney General (“AAG”) of the Criminal Division of the U.S. Department of Justice (“DOJ”), announced the launch of the Division’s Pilot Program on Compensation...more
Can a new Department of Justice enforcement approach make clawback policies covering criminal activities a best practice? The DOJ is implementing a new policy under which prosecutors will make clawback policies for...more
The government's focus on clawbacks is at a fever pitch. At the Practicing Law Institute's SEC Speaks conference earlier this month, senior officials within the SEC's Division of Enforcement emphasized the agency's increasing...more
What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more
This week, in this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI), I am exploring the need for federal contractors to maintain their status as “Responsible Contractors” and...more
In Wallace v. Andeavor Corp., the U.S. Fifth Circuit Court of Appeals affirmed the grant of summary judgment to an employer on a former vice president’s Sarbanes-Oxley Act (SOX) whistleblower claim...more
In Wadler v. Bio-Rad Laboratories, Inc., No. 17-16193, 2019 WL 924827 (9th Cir. Feb. 26, 2019), the United States Court of Appeals for the Ninth Circuit held that statutes, including the Foreign Corrupt Practices Act...more
In Wadler v. Bio-Rad Laboratories, Inc., the U.S. Court of Appeals for the Ninth Circuit adopted a limited, plain meaning construction of the types of reports that are protected by the Sarbanes-Oxley Act’s (SOX) whistleblower...more
A California federal court—in Erhart v. BofI Holding, Inc., 2017 U.S. Dist. LEXIS 14755, Case No. 15-cv-02287 (S.D. Cal. Sept. 11, 2017)—recently denied BofI Federal Bank’s (“BofI’s”) motion to dismiss the Sarbanes-Oxley...more
On April 12, 2017, the Third Circuit partially revived a former in-house attorney’s whistleblower retaliation lawsuit against his previous employer. Danon v. Vanguard Group, Inc., No. 16-cv-2881....more
On March 8, 2017, a split three-judge panel of the Ninth Circuit Court of Appeals affirmed a Northern District of California decision declining to dismiss a Dodd-Frank whistleblower retaliation claim because the plaintiff did...more
As we look across the corporate governance landscape and focus on the spikes of corporate scandals, I started to wonder if there was any pattern or trend to the nature of corporate scandals....more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
When Congress passed the Sarbanes-Oxley and Dodd-Frank Acts, it included protections for employees who blow the whistle on wrongdoing by their employers. However, those whistleblower protections don’t apply to every report of...more
Section 304 of the Sarbanes-Oxley Act of 2002 (15 U.S.C. § 7243) requires CEOs and CFOs to repay bonuses, incentive- and equity-based compensation, and profits realized on the sale of securities received in the 12 months...more