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Whistleblowers Incentives

Fox Rothschild LLP

Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

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The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for the upcoming fiscal...more

Proskauer Rose LLP

Top 10 Whistleblowing and Retaliation Events of 2024

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Following our annual tradition — which started over a decade ago — we are analyzing the year's 10 most significant whistleblower and retaliation events. As you'll see, in 2024, actions taken by a range of courts and...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2024

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Mayer Brown

DOJ Antitrust Division’s Latest Compliance Guidance: Now Covering Civil Implications, Whistleblowing, Ephemeral Messaging, and AI

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The US Department of Justice’s (DOJ) Antitrust Division recently updated its guidance explaining how it currently evaluates, and will evaluate going forward, companies’ antitrust compliance programs when making criminal...more

DLA Piper

DOJ’s Updated Antitrust Compliance Guidance Focuses on AI, Ephemeral Messaging, and Whistleblower Protections

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The US Department of Justice (DOJ)'s Antitrust Division recently updated its guidance on the evaluation of corporate compliance programs for criminal antitrust violations (the Antitrust ECCP), which federal prosecutors use to...more

ArentFox Schiff

Recent Updates to the DOJ’s Evaluation of Corporate Compliance Programs

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This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility...more

Wiley Rein LLP

DOJ’s Corporate Whistleblower Pilot Program Hits the Ground Running: Is Your Compliance Program Ready?

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The U.S Department of Justice’s (DOJ or Department) Corporate Whistleblower Awards Pilot Program (Pilot Program) has hit the ground running, reportedly triggering more than 100 reports since it went live on August 1, 2024....more

Stevens & Lee

Intent Required Under the Anti-Kickback Statute: Supreme Court Lets Stand Second Circuit’s Decision in the McKesson Case

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On Oct. 7, the U.S. Supreme Court denied a petition for review and let stand a widely watched Second Circuit Court of Appeals decision in which the court ruled that the term “willfully” as used in the Anti-Kickback Statute...more

Vinson & Elkins LLP

Supreme Court Declines to Revisit Limitations on Anti-Kickback Statute: What This Means for Enforcement of Corruption, Kickbacks...

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On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Foley & Lardner LLP

DOJ Stresses AI Risk and Whistleblower Protection in Revised Corporate Compliance Guidance

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On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more

Adams & Reese

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Mintz

DOJ Issues its Highly Anticipated Whistleblower Awards Pilot Program

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In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more

Epstein Becker & Green

DOJ Launches the Corporate Whistleblower Awards Pilot Program

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On August 1, 2024, the Department of Justice (“DOJ”) launched the Corporate Whistleblower Awards Pilot Program (“Pilot Program”), a three-year initiative managed by the Criminal Division’s Money Laundering and Asset Recover...more

Baker Donelson

Update: DOJ Launches Corporate Whistleblower Awards Program

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In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot...more

Paul Hastings LLP

Off to the Races: DOJ Offers New Incentives for Whistleblowers and Companies to Report Misconduct

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Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more

Mitratech Holdings, Inc

Ethics on the Line: Hotlines in Canada vs. the US; the Impact of the Whistleblower Act on Corporate Culture

We’ve talked before about how speak-up culture is on the rise; 6,000 more anonymous hotline reports were filed in 2023 than 2022, according to the respondent of Mitratech’s 2024 State of Ethics Reporting Hotlines....more

Cadwalader, Wickersham & Taft LLP

DOJ Announces Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the U.S. Department of Justice (“DOJ”) officially unveiled its Corporate Whistleblower Awards Pilot Program (the “Program”). The three-year pilot program aims to broaden the range of corporate misconduct...more

K&L Gates LLP

How the Serious Fraud Office's Ambitious Five-Year Strategy Will Impact Businesses

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The Serious Fraud Office (SFO) recently published its new five-year strategy for 2024-2029 (the Strategy), setting out its ambitious aspirations to become a “pre-eminent specialist, innovative and collaborative agency which...more

K&L Gates LLP

Federal Agencies Have Placed a Heightened Priority on Whistleblowers and Speedy Cooperation

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As new areas of the law emerge, driven in part by technology and the free flow of information, federal agencies are becoming more aggressive with a tried and true carrot-and-stick approach to law and regulatory enforcement. ...more

Gardner Law

DOJ Enforcement Insights: Key Strategies to Mitigate Risks

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The DOJ had a record year, and we reviewed FCA enforcement action trends to identify trends to help you stay informed and proactive in your compliance efforts. This alert summarizes key takeaways from Amanda Johnston’s recent...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

UK’s View Across The Pond At U.S. Whistleblower Program Success – Time To Incentivize Tipsters?

Several recent developments may spark a renewed effort to incentivize United Kingdom (UK)-based whistleblowers who frequently provide tips to U.S.-based agencies, such as the Security and Exchange Commission (SEC). The...more

Cooley LLP

Addressing Workplace Complaints: A Critical Step in Light of Whistleblower Incentives

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Prosecutors and regulators have recently offered significant financial rewards to whistleblowers to come forward in an effort to spur corporate enforcement. But whistleblowers aren’t made overnight – many times they are...more

Fisher Phillips

Feds Encourage Companies to Come Clean on Criminal Conduct and Reward Whistleblowers for Reporting Wrongdoing: Key Takeaways for...

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Federal prosecutors are exploring new ways to encourage business leaders to invest in their corporate compliance programs. Indeed, a Department of Justice official recently announced several new programs incentivizing...more

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