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Reporting Requirements Whistleblower Protection Policies

Jones Day

NDIL Launches Pilot Program to Encourage Individual Self-Disclosure of Organizational Misconduct

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The Development: On September 16, 2024, the U.S. Attorney's Office for the Northern District of Illinois ("NDIL") announced its six-month Individual Self-Disclosure Pilot Program for Organizational Misconduct ("Pilot...more

Womble Bond Dickinson

DOJ Updates Its Corporate Compliance Programs Guidance

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On September 23, 2024, the Criminal Division of the U.S Department of Justice (“DOJ”) released revised Evaluation of Corporate Compliance Programs guidance (“September 2024 Guidance), last updated in March 2023....more

Pillsbury Winthrop Shaw Pittman LLP

From AI Doomers to E/Accs: How SB 1047 and the 38 AI Laws in California Are Shaping Future AI Law

California’s Safe and Secure Innovation for Frontier Artificial Intelligence Models Act is one of the first significant regulations of artificial intelligence in the United States that, if signed, would place liability on the...more

McDermott Will & Emery

DOJ Makes Key Revisions to Corporate Compliance Program Guidance

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On September 23, 2024, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance (ECCP). Changes to the ECCP build on themes that the DOJ has been emphasizing for some time, including...more

Sheppard Mullin Richter & Hampton LLP

DOJ Announces Changes to Guidance on Corporate Compliance Programs, Updates on Whistleblower Program

In an address this week to the Society of Corporate Compliance and Ethics, Principal Deputy Assistant Attorney General Nicole M. Argentieri of the Department of Justice’s (“DOJ”) Criminal Division, highlighted several updates...more

Foley & Lardner LLP

SEC’s Focus on Whistleblower Protection Practices Continues

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On September 9, 2024, the U.S. Securities and Exchange Commission (SEC) announced that it settled charges against seven public companies for alleged violations of Securities Exchange Act Rule 21F-17. According to the SEC,...more

Seward & Kissel LLP

Recent SEC Enforcements for Violations of Whistleblower Protection Rule

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On September 9, 2024, the Securities and Exchange Commission (“SEC”) announced it settled enforcement actions against seven public companies for alleged violations of its whistleblower protection rule in their...more

Ballard Spahr LLP

SEC Announces Settlements with Seven Public Companies for Violations of Exchange Act Whistleblower Protections in Employee and...

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The SEC has begun to bring enforcement actions against companies whose employment and client agreements could appear to infringe on the right to report cases in violation of Section 21f-17(a) of the Exchange Act. On September...more

Jenner & Block

Client Alert: Key Takeaways from the SEC’s Latest Enforcement Sweep Regarding Violations of the Whistleblower Protections Rule

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Earlier this week, the SEC announced an enforcement sweep charging seven public companies with violating the whistleblower protections rule in various employment-related agreements. These charges reflect the SEC’s continuing...more

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

NAVEX

Celebrating World Whistleblower Day 2024

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“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

White & Case LLP

EU establishes harmonized enforcement and penalties for sanctions violations

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The EU has adopted a new directive which establishes EU-wide rules for defining criminal offences and penalties related to the violation of EU sanctions. A stricter regulatory environment and closer scrutiny is expected as...more

Kohn, Kohn & Colapinto LLP

FinCEN Head Praises New AML Whistleblower Program

The passage of the Anti-Money Laundering (AML) Whistleblower Improvement Act in December 2022 was heralded by whistleblower advocates as a major development which would transform the ability of the U.S. to crack-down on money...more

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

A&O Shearman

Announcement of new DOJ Whistleblower Policy

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...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

Maynard Nexsen

Unanimous Supreme Court Bolsters Whistleblower Claims

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On February 8, 2024, the Supreme Court ruled that whistleblowers have a lower hurdle to clear to maintain their retaliation claims, even when they are terminated as a part of a company reorganization. The unanimous decision...more

Jenner & Block

Client Alert: Calling (Some but Not All) Whistleblowers: Understanding SDNY’s New Whistleblower Pilot Program

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On January 10, 2024, US Attorney Damian Williams announced a new Whistleblower Pilot Program for the US Attorney’s Office of the Southern District of New York (SDNY). The program is designed to proactively uncover criminal...more

Kohn, Kohn & Colapinto LLP

FinCEN’s New Rules for Reporting Beneficial Owners Create Opportunity for Whistleblowers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is enacting new rules for January 1, 2024, requiring companies to report their beneficial owners to FinCEN. Violations of these new...more

Kohn, Kohn & Colapinto LLP

SEC, CFTC Pass $2 Billion Award Milestone but Reforms are Still Needed

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

Morrison & Foerster LLP

Top 5 SEC Developments (September 2023)

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In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources....more

Latham & Watkins LLP

German Whistleblower Protection Act: Considerations for Companies

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Companies operating in Germany should implement reporting mechanisms or adapt their existing ones to comply with the new legal requirements. The German Whistleblower Protection Act (Hinweisgeberschutzgesetz — HinSchG)...more

Latham & Watkins LLP

New Whistleblower Protections in France: Considerations for Companies

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Companies operating in France should implement or adapt their reporting mechanisms to comply with the new requirements. On 1 September 2022, new protections for whistleblowers in France entered into force. The protections...more

McDermott Will & Emery

Whistleblowing

Gesetzentwurf der Bundesregierung für ein Hinweisgeberschutzgesetz - Die Bundesregierung hat am 27. Juli 2022 einen Entwurf für ein „Gesetz für einen besseren Schutz hinweisgebender Personen sowie zur Umsetzung der...more

Faegre Drinker Biddle & Reath LLP

Recent Developments in Irish Employment Law

There have been several developments in Irish employment law in recent months. These developments include requirements for gender pay gap reporting, expanded protections for whistleblowers, family leave and flexible work...more

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