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Whistleblowers Voluntary Disclosure

The Volkov Law Group

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

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While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

Mintz - Health Care Viewpoints

EnforceMintz – DOJ Policy Developments in 2024 Seek to Motivate More Voluntary Self-Disclosures

Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more

The Volkov Law Group

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

The Volkov Law Group on

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Kohn, Kohn & Colapinto LLP

Hidden Whistleblower Disclosure Units: Self-Regulatory Organizations

Despite the immense success of, and corresponding public interest in, the Securities and Exchange Commission (SEC) Whistleblower Program, one element of the program remains little understood: whistleblowers who report...more

Holland & Knight LLP

Do You Hear What I Hear? DOJ, SEC Continue Promoting Merits of Self-Reporting in 2024

Holland & Knight LLP on

2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings, we take a quick look at how the SEC treats self-reporting and how that differs...more

DLA Piper

Institutional Investor Newsletter: 2024 End-of-Year Roundup

DLA Piper on

A recent trend in continuation vehicles involves traditional private equity sponsors serving as the “lead investor” in lieu of, or in addition to, more traditional secondary buyers and institutional investors. This expansion...more

Mitratech Holdings, Inc

5 Trends Shaping Whistleblower Regulations in 2025

Mitratech Holdings, Inc on

In 2025, whistleblower regulations are poised for major evolution, reflecting a renewed commitment to transparency and accountability. The Ethics and Compliance Initiative (ECI) 2023 survey revealed a startling statistic:...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

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Mintz

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

Mintz on

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

Bracewell LLP on

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

Adams and Reese LLP

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Torres Trade Law, PLLC

Noteworthy FCPA Enforcement Developments

Torres Trade Law, PLLC on

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

Cooley LLP

EDNY Launches New Whistleblower Non-Prosecution Pilot Program

Cooley LLP on

On September 17, 2024, the US Attorney’s Office for the Eastern District of New York (EDNY) announced a new pilot program that offers non-prosecution agreements (typically referred to as NPAs) to individuals who voluntarily...more

Foley & Lardner LLP

DOJ Stresses AI Risk and Whistleblower Protection in Revised Corporate Compliance Guidance

Foley & Lardner LLP on

On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...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

Katten Muchin Rosenman LLP

Chicago United States Attorney's Office Launches Pilot Program to Encourage Self-Disclosure

On September 16, the US Attorney's Office for the Northern District of Illinois (NDIL) announced the launch of its Individual Self-Disclosure (ISD) Pilot Program. The program offers non-prosecution agreements to qualifying...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

Fenwick & West LLP

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

Fenwick & West LLP on

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

Hogan Lovells

It’s the final countdown... for self-disclosure under DOJ’s amended Corporate Enforcement Policy

Hogan Lovells on

The recent amendment to the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) of the Department of Justice’s (DOJ’s) Criminal Division expects companies to self-disclose allegations of misconduct within 120...more

McDermott Will & Emery

US Attorney’s Office in California Announces Voluntary Self-Disclosure and Whistleblower Program for Corporate, Financial Crimes

McDermott Will & Emery on

On August 23, 2024, the US Attorney’s Office for the Central District of California, which is the largest judicial district in the United States, announced a new Voluntary Self-Disclosure and Whistleblower Pilot Program. The...more

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

Proskauer Rose LLP on

Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

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