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Whistleblower Awards Whistleblowers

Parker Poe Adams & Bernstein LLP

What DOJ's Latest Guidance on Artificial Intelligence Corporate Compliance Means for Businesses

The U.S. Department of Justice (DOJ) recently updated its Evaluation of Corporate Compliance Programs (ECCP), which prosecutors consider when investigating, charging, and negotiating plea or other agreements with...more

Kohn, Kohn & Colapinto LLP

Whistleblowers are Key to CFTC’s Priority of Combating Voluntary Carbon Market Fraud

Voluntary Carbon Markets (“VCMs”) are touted as a promising solution to rising global carbon emissions. They have the potential to strengthen climate technology and promote projects that reduce carbon dioxide emissions and...more

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

Fisher Phillips

The Whistleblowing Just Got Louder: 8 Things Employers Should Do in Response to Feds’ New Whistleblower Awards Program

Fisher Phillips on

A new initiative rolled out by federal officials this summer can reward corporate whistleblowers with up to $30 million – which means it is incumbent upon your organization to step up your game when it comes to corporate...more

Stevens & Lee

After the Whistle: Constitutional Challenges to Qui Tam Actions

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Whenever there is a pot of money up for grabs, people will inevitably want more than their fair share. And when that money is doled out through government contracts, opportunities for fraud abound. The government can...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

Fenwick & West LLP on

In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

Woods Rogers

The Truth Shall Set You Free: Western District of Virginia Unveils Whistleblower Pilot Program

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Much has been written in recent months about the Department of Justice’s national Whistleblower Rewards Program, including a recent article I co-authored with Mike Gill entitled 7 Strategies to Comply with the DOJ’S New...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

Bradley Arant Boult Cummings LLP

Whistleblower Language in Separation Agreements Results in Large Settlements with SEC

On September 9, 2024, the Securities and Exchange Commission (SEC) announced settlements with seven public companies relating to their use of separation agreements that the SEC says violate whistleblower protection rules by...more

Mintz

DOJ Reinforces Emphasis on Voluntary Self-Disclosure With Latest Updates to the Evaluation of Corporate Compliance Programs...

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On September 23, 2024, the Criminal Division of the United States Department of Justice (“DOJ” or the “Department”) revised its Evaluation of Corporate Compliance Programs guidance (the “ECCP”)....more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Eversheds Sutherland (US) LLP

DOJ emphasizes importance of AI risk mitigation, whistleblower protections, and clawback compensation policies

Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP). These updates discuss, for the first time,...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

Torres Trade Law, PLLC

Noteworthy FCPA Enforcement Developments

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The Department of Justice really wants violators of the Foreign Corrupt Practices Act (FCPA) to come forward: following a January 2023 revision of its Corporate Enforcement Policy that incentivized voluntary self-disclosure,...more

Womble Bond Dickinson

DOJ Updates Its Corporate Compliance Programs Guidance

Womble Bond Dickinson on

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

Fenwick & West LLP

SEC Settles Seven Whistleblower Protection Actions

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On September 9, the SEC settled charges against seven public companies for violations of the whistleblower protection rule. According to the SEC’s orders, among other things, these companies violated Rule 21F-17(a) by...more

Kohn, Kohn & Colapinto LLP

Fifth Circuit Ruling on Whistleblower Awards from Bankruptcy Collections Underscores Shortcoming With SEC Program

Whistleblowers who exposed what has been called “one of the biggest frauds in Texas history” are not eligible to receive Securities and Exchange Commission (SEC) whistleblower awards based on the collections recovered in a...more

BakerHostetler

7 More US Attorneys’ Offices Issue Whistleblower Non-Prosecution Pilot Programs

BakerHostetler on

There was a flurry of DOJ whistleblower program activity over the last two weeks as the U.S. Attorneys’ Offices for the Eastern District of New York (EDNY Program), District of New Jersey (DNJ Program), Southern District of...more

Fenwick & West LLP

DOJ ‘Upping the Ante’ for Corporate Self-Disclosure with New Corporate Whistleblower Awards Pilot Program

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Earlier in 2024, DOJ’s Criminal Division announced a new Corporate Whistleblower Awards Pilot Program granting whistleblower awards to individuals who provide information in four priority areas. ...more

McGuireWoods LLP

“Call Us Before We Call You”:  DOJ’s New Corporate Whistleblower Awards Pilot Program

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On September 17, 2024, Deputy Assistant Attorney General Nicole Argentieri stressed the intense focus placed by the U.S. Department of Justice (DOJ or the Department) on incentivizing companies to maintain healthy corporate...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

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

WilmerHale

SEC Continues Scrutiny of Provisions That Might Impede Whistleblowers

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On September 9, 2024, the Securities and Exchange Commission (SEC) announced settled charges against seven public companies for violations of certain whistleblower protections provided by Rule 21F-17 under the Securities...more

Dorsey & Whitney LLP

Companies Subject to U.S. Jurisdiction Should not Restrict Personnel from Being SEC Whistleblowers, or Receiving SEC Whistleblower...

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SEC rules prohibit taking “any action” to impede an individual from communicating directly with the SEC about a possible securities law violation, including by enforcing, or threatening to enforce, a confidentiality...more

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