News & Analysis as of

Whistleblowers Securities and Exchange Commission (SEC) Corporate Misconduct

Lathrop GPM

Trump Executive Order Pausing FCPA Enforcement: Have Legal Requirements Changed?

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One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...more

Benesch

A Survey of Recent Enforcement Actions, Trends & Priorities

Benesch on

The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more

Venable LLP

Defense Contractor Resolves DOJ and SEC FCPA, FCA, Export Controls Violations for $950 Million

Venable LLP on

In October 2024, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced settlements with Raytheon Company, a division of multinational defense contractor RTX, over defective pricing and...more

Foley Hoag LLP - White Collar Law &...

Anticorruption and FCPA Enforcement: Takeaways and Lessons Heading into 2025

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Foley & Lardner LLP

Does Your Company Discourage Employees from Being Whistleblowers? The SEC May Think So!

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The Dodd-Frank Wall Street Reform and Consumer Protection Act, which was enacted in 2010 in response to the 2008 financial crisis, added protections for whistleblower activity to the Securities Exchange Act of 1934 (“Exchange...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

Vinson & Elkins LLP

Whistleblowers Wanted: Proliferation of DOJ Whistleblower Policies Invites Harmonization by the Trump Administration

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As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more

Holland & Knight LLP

Ringing the (Jingle) Bell: Whistleblower Program 2024 Recap

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Whistleblower programs are the gifts that keep giving to enforcement agencies, driving a record number of cases, sanctions and awards across multiple agencies. In this ninth installment of Season's Readings, we revisit some...more

Mitratech Holdings, Inc

Turning the SEC Enforcement Results into Opportunity: Historic Penalties Signal a Compliance Shift

The SEC’s fiscal year 2024 enforcement results signal a pivotal moment for U.S. capital markets. Despite a 26% decline in the total number of enforcement actions compared to 2023 (sitting at a total of 583 for this year), the...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from Venice – Part 3: Straight from the Lion’s Mouth and Whistleblower Programs

In the final part of the Compliance Lessons from Venice series, we focus on one of Venice’s earliest tools for addressing misconduct: a reporting system predating modern whistleblower programs. Known as the Lion’s Mouth, this...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments – Q3 2024

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On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Mitratech Holdings, Inc

Avoiding Corporate Skeletons in the Closet: The Importance of Ethics Hotlines

Mitratech Holdings, Inc on

Ensure a skeleton-free zone in your organization by maintaining accountability with ethics hotlines. Corporate scandals can shake the trust and reputation of any company. Take, for example, the recent case where the...more

Thomas Fox - Compliance Evangelist

Argentieri on the DOJ’s Corporate Whistleblower Awards Pilot Program

The Department of Justice (DOJ) recently unveiled the Corporate Whistleblower Awards Pilot Program (CWA) to bolster corporate enforcement efforts. Although the program has only been operational for a few weeks, it has already...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Whistleblower Update: SEC, DOJ Still Focusing on Employment Agreements and Written Policies, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) brought more actions targeting regulated entities for recordkeeping violations related to employees using noncompany communications platforms, and both the SEC and the U.S....more

Thomas Fox - Compliance Evangelist

Addressing Pre-taliation

One of the most talked about subjects in corporate compliance is the issue of pre-taliation—an increasingly common enforcement target by the U.S. Securities and Exchange Commission (SEC). Matt Kelly and I did a recent podcast...more

The Volkov Law Group

Episode 335 -- The New DOJ Whistleblower Program

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How will the DOJ's new corporate whistleblower pilot program reshape the enforcement of corporate criminal conduct? In this episode of Corruption, Crime, and Compliance, Michael Volkov explores the Department of Justice's...more

Foley & Lardner LLP

Understanding the Risk vs. Reward of Department of Justice’s Corporate Criminal Whistleblower Awards Pilot

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The Securities & Exchange Commission, the Department of Health & Human Services, and other agencies have long had established bounty programs that reward successful tipsters. On August 1, 2024, the Department of Justice’s...more

Proskauer - Whistleblower Defense

SEC Awards Two Whistleblowers More Than $98 Million

On August 23, 2024, the SEC announced payment of more than $98 million in total to two whistleblowers who provided the SEC with information and assistance that led to successful enforcement actions by the SEC and another...more

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

White & Case LLP on

In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

Holland & Hart LLP

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

Holland & Hart LLP on

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

Jones Day

DOJ Announces Corporate Whistleblower Awards Pilot Program

Jones Day on

The Development: On August 1, 2024, the Department of Justice's ("DOJ") Criminal Division announced its Corporate Whistleblower Awards Pilot Program ("Pilot Program"), designed to reward whistleblowers who report information...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

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Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

BakerHostetler

DOJ Corporate Whistleblower Awards Pilot Program

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DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more

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