News & Analysis as of

Financial Institutions Whistleblower Protection Policies Whistleblowers

Quarles & Brady LLP

Expansion of DOJ White Collar Whistleblower Programs to Local US Attorney’s Offices

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In August, the Department of Justice’s Criminal Division announced the launch of a Corporate Whistleblower Awards Pilot Program, building off an earlier pilot program started in the Southern District of New York to encourage...more

Ballard Spahr LLP

Are Whistleblower Protection Violations the New SEC Sweep?

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The Securities and Exchange Commission (SEC) continues to investigate companies for including language in their employment and separation agreements or retail client settlement agreements that potentially discourages...more

Woods Rogers

CFPB Warns Employee Confidentiality Agreements May Violate Whistleblower Protections

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The Consumer Financial Protection Bureau (CFPB) recently issued the Consumer Financial Protection Circular 2024-04 warning financial institutions that broad employee confidentiality agreements may violate the whistleblower...more

Ballard Spahr LLP

DOJ Unveils Corporate Whistleblower Awards Pilot Program – With Implications for Financial Institutions and AML/CFT Compliance...

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On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more

Troutman Pepper

Regulators Prowl for Financial Firms That Wield NDAs to ‘Muzzle’ Whistleblowers

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In a note to clients, the law firm Troutman Pepper Hamilton Sanders said that, while the legislation bars employers from taking actions that “discriminate against” whistleblowers, it’s a leap for the agency to interpret the...more

Holland & Knight LLP

Justice Department Announces New Corporate Whistleblower Pilot Program

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After announcing at the ABA White Collar Crime Conference last winter that it would engage in a months-long "policy sprint," the U.S. Department of Justice (DOJ or Department) released its Corporate Whistleblower Awards Pilot...more

Kohn, Kohn & Colapinto LLP

The Double-Edged Impact of AI Compliance Algorithms on Whistleblowing

As the implementation of Artificial Intelligence (AI) compliance and fraud detection algorithms within corporations and financial institutions continues to grow, it is crucial to consider how this technology has a twofold...more

Cranfill Sumner LLP

DOJ Announces New Whistleblower Reward Program for Individuals to Combat Significant Corporate or Financial Misconduct

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During a March 7, 2024, speech at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced that the United States Department of Justice (“DOJ”) is launching a...more

McDermott Will & Emery

DOJ Doubles Down on Corporate Enforcement With New Whistleblower Program

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During the 2024 American Bar Association National Institute on White Collar Crime (the 2024 White Collar Conference) earlier this month, US Attorney General (AG) Merrick Garland, US Deputy Attorney General (DAG) Lisa Monaco,...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Plan To Offer Monetary Rewards for Whistleblowers

On March 7, 2024, Deputy Attorney General (DAG) Lisa Monaco announced that the Department of Justice (DOJ) will soon launch a new monetary reward program for people who provide information about corporate or financial...more

Troutman Pepper

Navigating the SEC's Whistleblower Enforcement Wave: A Guide for Financial Institutions — The Consumer Finance Podcast

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In this episode of The Consumer Finance Podcast, Chris Willis is joined by Partners Sheri Adler and Mary Weeks to discuss the recent uptick in SEC enforcement activity related to whistleblowers. They focus on the implications...more

DarrowEverett LLP

Actions vs. J.P. Morgan, Monolith Serve as SEC Compliance Check Reminders

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The Securities and Exchange Commission (SEC) recently settled charges against J.P. Morgan Securities LLC (JPMS) for impeding hundreds of advisory clients and brokerage customers from reporting potential securities law...more

K&L Gates LLP

SEC Enforcement Targets Anti-Whistleblower Practices in Financial Firm's Release Agreements With Retail Clients

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As the year gets underway, the Securities and Exchange Commission (SEC or Commission) is continuing its ongoing enforcement efforts to target anti-whistleblower practices by pursuing a broader range of entities and...more

Seyfarth Shaw LLP

SDNY Breaks with Tradition in New Whistleblower Pilot Program

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As usual, the U.S. Attorney’s Office for the Southern District of New York (the “SDNY”) is on the hunt for fraudsters and other white collar criminals. Though the Department of Justice has rewarded corporations for...more

Orrick, Herrington & Sutcliffe LLP

SDNY pilots new whistleblower program to protect individuals

On January 12, the SDNY launched its Whistleblower Pilot Program to protect individuals who report company wrongdoing from any future prosecution by the DOJ. The SDNY issued this program to encourage the “voluntary...more

Littler

New Anti-Money Laundering Whistleblower Improvement Act Expands Coverage and Strengthens Incentives for Whistleblowers

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On December 29, 2022, President Biden signed a new whistleblower law that significantly increases the risk and cost of whistleblower claims for domestic and overseas financial services institutions that must be cognizant of...more

Goodwin

Stress Test Scenarios Released for 2022

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In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Kohn, Kohn & Colapinto LLP

Momentum Grows for Fixing the AML Whistleblower Law

When the Anti-Money Laundering Whistleblower Act (“AML Act”) became law on January 1, 2021, some commentators praised it as a breakthrough. The law was modelled on the highly successful Dodd-Frank Act (“DFA”) and shared...more

Ballard Spahr LLP

The New BSA Whistleblower Law: What You Need to Know

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Today’s episode features a discussion of the new whistleblower provisions in the Anti-Money Laundering Act of 2020. We’ll discuss the types of businesses covered, who can be a whistleblower under the Act, the increased...more

Holland & Knight LLP

Key Provisions of the Anti-Money Laundering Act of 2020

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The Anti-Money Laundering Act of 2020 (AMLA 2020) became law on Jan. 2, 2020, when Congress overrode President Donald Trump's veto of the National Defense Authorization Act. AMLA 2020 is the most consequential anti-money...more

Miles & Stockbridge P.C.

Top 5 Changes To Anti-Money Laundering Requirements

On January 1, 2021, the National Defense Authorization Act became law after Congress overrode the President’s veto. As highlighted below, Congress enacted a variety of key provisions that create significant and sweeping...more

BCLP

Whistleblowing: Regulatory health check for financial institutions’ whistleblower frameworks

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On 11 May 2020, Practical Law published a new practice note, written by Polly James, a partner in our Investigations, Financial Regulation and White Collar practice group, on whistleblower frameworks for financial...more

Hogan Lovells

New EU Whistleblowing Directive – what UK financial services firms need to know

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On 7 October 2019, the Council of the European Union formally adopted a new Directive on the protection of persons who report breaches of Union law. The Directive was published in the Official Journal of the European Union on...more

A&O Shearman

UK Conduct Regulator Wants Improvements to Banks' Whistleblowing Arrangements

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The U.K. Financial Conduct Authority has published the outcome of its review of firms' whistleblowing arrangements. The FCA has reviewed how retail and wholesale banks have implemented its whistleblowing rules by looking at...more

Ballard Spahr LLP

Case Highlights Potential Protections for BSA Whistleblowers

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A recent court opinion emphasizes the sensitive issues involved in terminating potentially difficult employees — or, from the employee’s or perhaps the government’s perspective, in terminating whistleblowers who were...more

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