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Whistleblower Protection Policies Internal Controls

Society of Corporate Compliance and Ethics...

Managing Whistlelbowers

Managing whistleblowers is always a hot topic, and you’ll find it on the agenda at the 2025 SCCE Annual Compliance & Ethics Institute. To provide a preview of what you will see if you join us in Nashville, we sat down with...more

Mitratech Holdings, Inc

Navigating International Whistleblower Protection Laws: Key Regulations Around the World

Foster better organizational transparency with insights into whistleblowing regulations and safeguards across the globe. Whistleblowers act as vigilant public advocates, exposing fraud and abuse. According to the...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

Fenwick & West LLP on

In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

BCLP

DOJ Updates Criteria for Review of Corporate Compliance Programs, Emphasizing AI Issues

BCLP on

On September 23, the Department of Justice updated the document it uses to evaluate a corporation’s compliance program in the context of wrongdoing by the corporation – the Evaluation of Corporate Compliance Programs, or...more

Dorsey & Whitney LLP

DOJ Updates the Evaluation of Corporate Compliance Program Memorandum, Emphasizing Emerging Technologies, Data Analytics, and...

Dorsey & Whitney LLP on

On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs policy (the “Updated ECCP”), building upon the March 2023 updates. Since 2017, DOJ has offered...more

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments - October 2023

Foley & Lardner LLP on

Eleventh Circuit Adopts “Totality of the Circumstances” Test for Showing Protected Activity Under SOX and Denies Whistleblower Petition for Review - In Ronnie v. Office Depot, LLC, --- F.4th ----, 2023 WL 6210623 (11th Cir....more

NAVEX

Hotline Benchmark Analysis – What a Deeper Analysis of 24 Issue Types Reveals

NAVEX on

Each year, NAVEX produces the Hotline & Incident Management Benchmark Report – a comprehensive assessment of trends in whistleblowing. This year, our analysis included 1.52 million reports across 3,430 organizations and is in...more

Society of Corporate Compliance and Ethics...

[Event] 11th Annual European Compliance & Ethics Institute - March 20th - 22nd, Amsterdam, Netherlands

In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more

Freeman Law

The False Claims Act: The Risks of Doing Business with the U.S. Government

Freeman Law on

The False Claims Act (FCA) was passed by Congress during the Civil War to punish defense contractors for fraud. Under the FCA, a government contractor who submits fraudulent invoices or induces the government to grant a...more

Barnea Jaffa Lande & Co.

Implications of European Whistleblower Protection Directive on Israeli Companies

By October, companies in the European Union employing at least 50 employees will be required to operate an internal reporting system for reporting misconduct that may indicate compliance violations. Furthermore, all companies...more

Orrick, Herrington & Sutcliffe LLP

Nuove Linee Guida Confindustria per la costruzione dei Modelli ex D.Lgs. 231/2001: principali novità

Dopo anni di attesa, sono state emanate le nuove “Linee Guida per la costruzione dei Modelli di organizzazione, gestione e controllo ai sensi del Decreto Legislativo 8 giugno 2001, n. 231” (le “Linee Guida”), con la medesima...more

Proskauer - Whistleblower Defense

ARB Affirms Dismissal of SOX Whistleblower Claim for Lack of Protected Activity

On December 17, 2020, the Administrative Review Board (“ARB”) of the U.S. Department of Labor affirmed the dismissal of a former employee’s whistleblower retaliation claim under Section 806 of SOX.  The ARB concluded that the...more

Proskauer - Whistleblower Defense

Third Circuit Confirms Limits on Scope of Protected Activity Under SOX

On July 16, 2020, the Third Circuit affirmed the dismissal of a former IT analyst’s whistleblower retaliation claim, holding that he lacked an objectively reasonable belief that his complaints implicated one of the enumerated...more

K2 Integrity

[Webinar] Mitigating Fraud Risk During COVID-19 - June 30th, 4:00 pm - 5:00 pm GMT

K2 Integrity on

During times of economic stress, organisations face heightened fraud risk from both within and outside their organisation. Now more than ever, it’s critical to have in place a robust anti-fraud strategy, effective monitoring...more

Polsinelli

Summary Judgment Decision in Long-Running Erhart SOX Case Limits the Scope of Protected Activity Under SEC Books and Records and...

Polsinelli on

On March 31, 2020, the U.S. District Court for the Southern District Court of California entered partial summary judgment in Erhart v. BofI Holding, Inc., a prominent, long-running whistleblower lawsuit under the...more

Mitratech Holdings, Inc

The Importance of Visibility and Control Within Compliance Functions

When we talk about visibility and control within a compliance department, they’re akin to the two sides of a coin. One can’t exist without the other, and both sides are essential for proper functioning of the department....more

Proskauer - Whistleblower Defense

SEC Awards Whistleblower More Than $4.5 Million

On May 24, 2019, the SEC announced payment of more than $4.5 million to a whistleblower who sent an anonymous tip to the company alleging significant wrongdoing and then submitted the same information to the SEC....more

Stinson - Corporate & Securities Law Blog

SEC Awards First Ever $4.5 Million to Internal Whistleblower

The SEC awarded more than $4.5 million to a whistleblower whose tip triggered the company to review the allegations as part of an internal investigation and subsequently report the whistleblower’s allegations to the SEC and...more

Polsinelli

Tenth Circuit Confirms that Compliance Employees Must Satisfy Heavier Burden to Obtain FCA Whistleblower Protection

Polsinelli on

On April 30, 2019, the U.S. Court of Appeals for the Tenth Circuit in United State ex rel. Reed v. KeyPoint Government Solutions affirmed the dismissal of an employee’s False Claims Act (FCA) whistleblower retaliation claim....more

Pillsbury Winthrop Shaw Pittman LLP

Time to Update Corporate Compliance Programs Following DOJ Guidance

Companies must now address three questions proactively. On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more

Thomas Fox - Compliance Evangelist

How Compliance Adds to the Bottom Line

I have long articulated that companies that have robust compliance programs are more efficient, better run and more profitable organizations. ...more

Thomas Fox - Compliance Evangelist

Tribute to Picasso: Phases of a Whistleblower Program

Just as Picasso had several phases of his career, the lifecycle of the Goldman Sachs internal whistleblower program may be getting ready to have more phases....more

Proskauer - Whistleblower Defense

S.D.N.Y. Dismisses Dodd-Frank Whistleblower Retaliation Claim

In one of the first cases to address the standard governing a motion for summary judgment in a Dodd-Frank whistleblower retaliation case, Judge Jed S. Rakoff ruled that two former executives of Vista Outdoor Inc. (the...more

Orrick, Herrington & Sutcliffe LLP

New French Anticorruption Legislation Affecting Large French and Foreign Groups of Companies and Their Top Management

On December 9th, 2016, France officially enacted the Law on transparency, anti-corruption and economic modernization (so-called "Sapin II bill") which introduces the following key changes...more

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