The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
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
On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more
On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more
On July 26, 2024, the SEC announced an award of more than $37 million to a whistleblower who first reported misconduct internally and subsequently provided information and assistance that led to a successful SEC enforcement...more
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
“Whistleblower”. Rarely has a term provoked such lively and varied reactions in the political, economic and social spheres – and even in households! Traitors for some, heroes for others, these people, who were never...more
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more
Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more
While most legal conferences may not be newsworthy, the American Bar Association’s National Institute on White Collar Crime is an exception. Indeed, the federal government’s chief law enforcers seem to treat this particular...more
On March 7, 2024, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s 39th National Institute on White Collar Crime. In her address, she announced a new, nationwide...more
On March 7, 2024, the U.S. Department of Justice (“DOJ”) announced that it will create a whistleblower rewards program under which individuals who report corporate misconduct can earn a share of any resulting DOJ forfeiture. ...more
On January 16, the U.S. Securities and Exchange Commission (SEC) announced a record $18 million sanction against JP Morgan for Rule 21F-17(a) violations, sending the strongest message yet that the SEC is cracking down on...more
SEC Chair Gary Gensler announced on October 25th that in the 2023 fiscal year, the Commission received a record number of 18,000 whistleblower tips. The SEC Whistleblower Program has grown rapidly and effectively since its...more
Combined, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have awarded more than $2 billion to whistleblowers. The agencies’ whistleblower programs, which were created...more
On September 19, 2023, the CFTC announced whistleblower awards totaling over $15 million to two whistleblowers who provided the CFTC with information that assisted the agency in bringing separate successful enforcement...more
On August 25, 2023, the SEC announced an award of more than $18 million to a whistleblower who first reported misconduct internally and subsequently provided information and assistance that led to a successful SEC enforcement...more
The proposed amendments to the rules governing the whistleblower program, if adopted, would reverse prior amendments and provide further and significant financial incentives for whistleblowers to report potential violations...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
On November 15, 2021, the SEC published its annual report to Congress covering the period from October 1, 2020 to September 30, 2021. The report was prepared by the SEC’s Office of the Whistleblower to summarize its...more
On October 15, 2021, the SEC’s Office of the Whistleblower announced multi-million dollar awards to two whistleblowers who provided the SEC with information that assisted the agency in bringing a successful enforcement...more
The Securities and Exchange Commission’s (SEC) whistleblower program hit a big milestone, topping $1 billion in awards in less than a decade (it began in 2012). ...more
The accelerated pace and size of awards to whistleblowers totaling more than $530 million in SEC Fiscal Year 2021 underscores the commitment to the whistleblower program under new SEC leadership. On September 15, 2021, the...more
On September 24, 2021, the SEC announced an approximately $36 million award to a whistleblower who provided critical information to the SEC that contributed to a successful enforcement action. ...more
Last week, the SEC announced accumulated awards of over $1 billion paid to 207 whistleblowers since its first award in 2012. Over $500 million was awarded in fiscal year 2021 alone. The SEC crossed the billion-dollar...more
On July 30, 2021, the SEC posted 14 Notices of Covered Actions, after which individuals have 90 calendar days to apply for a whistleblower award. As discussed in our prior post, the SEC publishes these Notices for cases in...more