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Securities and Exchange Commission (SEC) Department of Justice (DOJ) Whistleblowers

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

Kohn, Kohn & Colapinto LLP

U.S. Attorney Office “Whistleblower” Programs Sow Confusion and Pose Risks to Corporate Whistleblowers

In recent weeks, a number of U.S. Attorneys’ Offices (USAOs) across the country have rolled out “Whistleblower Pilot Programs” offering the potential of non-prosecution agreements in exchange for voluntary self-disclosure of...more

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

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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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 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

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

Adams and Reese LLP

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

A&O Shearman

SEC Reaches Three Separate Resolutions In Continued Focus On Whistleblowers And Rule 21F-17(a)

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In September 2024, the Securities and Exchange Commission (“SEC” or “the Commission”) resolved three separate actions against corporate entities for reaching agreements with employees, potential employees, and clients that,...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

Wiley Rein LLP

SEC Is Looking at Your Vendor Contracts for Whistleblower Restraints – Fines Seven More Companies

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The U.S. Securities and Exchange Commission (SEC) recently settled charges against seven companies for violating SEC Rule 21F-17(a), which prohibits conduct that hinders whistleblowing to the SEC. The settlements focus on...more

BCLP

Incentivising Whistleblowers: What Does the Future Hold in the UK and the US for Whistleblower Protection and Incentivisation?

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In the UK, it has not historically been part of the fabric of our legal and regulatory system to pay whistleblowers who provide evidence to authorities who are investigating potential breaches of law or regulation....more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...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

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

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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

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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

Jones Day

DOJ Announces Corporate Whistleblower Awards Pilot Program

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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

Lowenstein Sandler LLP

DOJ’s New Whistleblower Policies Will Bring Increased Scrutiny to Businesses in the Financial and Health Care Industries and Those...

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Earlier this month, the U.S. Department of Justice (DOJ) announced its Corporate Whistleblower Awards Pilot Program (Program). The Program—which will last for three years—is designed to incentivize, through money awards,...more

ArentFox Schiff

Investigations Newsletter: DOJ Launches Corporate Whistleblower Awards Pilot Program

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DOJ Launches Corporate Whistleblower Awards Pilot Program - On August 1, the US Department of Justice (DOJ) announced the details of its new Corporate Whistleblower Awards Pilot Program. According to the DOJ, the...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

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

WilmerHale

Rewarding Whistleblowers Will Only be Effective as Part of a Wider Package of Reforms

WilmerHale on

Serious Fraud Office (SFO) Director Nick Ephgrave has consistently touted the benefits of offering financial rewards to whistleblowers. With the FCA also considering its position on financial incentivisation, and a supportive...more

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