The EU Whistleblowing Directive
Six Steps Companies Can Take to Manage the Risk of Using Generative AI
Helpline Usage (or Lack Thereof)
Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean
Encouraging Internal Whistleblowers
Encouraging Employee Feedback and Internal Whistleblowing
Integrity Matters: Fraud Trends for 2022, Ep. 1
JONES DAY TALKS®: The eBay Cyberstalking Case: Mitigating the Compliance Risks of Employee Misconduct
Doing Business in the European Union | Reporting Systems and the Importance of Culture & Language
Doing Business in the European Union | EU Directive, Following Up With The Whistleblower
Susan Roberts on Creating a Compliance Program Book
Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting
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
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
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
On November 14, 2023 the Securities and Exchange Commission (SEC) released its annual Office of the Whistleblower Report to Congress for fiscal year 2023 (October 1, 2022-September 30, 2023). This report highlighted several...more
Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more
This year is proving to be a record-setting year for whistleblowers. On October 22, the U.S. Securities and Exchange Commission announced it had awarded an unprecedented $114 million to a whistleblower who, the SEC says,...more
How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more
In Houston, we have experienced energy companies laying off upwards of 30% of their workforce, both in the US and abroad. Employment separations can be one of the trickiest maneuvers to manage in the spectrum of the...more
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more
The SEC’s most recent whistleblower awards highlight the importance of internal reporting to a company’s compliance program and especially how a company investigates and responds to such reports. On May 24, 2019, the SEC...more
The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more
On March 8, 2017, the United States Court of Appeals for the Ninth Circuit held that the Dodd Frank anti-retaliation provisions protect individuals who complain internally and are not strictly limited to those individuals who...more
The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more
The headlines lit up this month when the Securities and Exchange Commission (SEC) issued its first-ever award to a whistleblower who wasn’t employed by the company on which he had blown the whistle. The award was a...more
On August 4th, the SEC delivered new guidance designed to answer once and for all one of the most important concerns of a potential whistleblower: “Where must I report to obtain protection from retaliation?” When...more
Last November, the U.S. Securities and Exchange Commission issued its Annual Report to Congress on the Dodd-Frank Whistleblower Program. It is clear that the program is going strong. Following are five key ways compliance...more