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Thomas Fox - Compliance Evangelist

Navigating Compliance in Interesting Times

I once had a boss whose catchphrase was ‘May you live in interesting times’. That applied back in the first decade of this century and I think it is even more appropriate now. In a world that often feels as if it is...more

World Law Group

2024 WLG Whistleblower Guide: Spain

World Law Group on

Is there a law to protect whistleblowers? If so, which law? Yes. Spanish Law 2/2023, of February 20, regulates the protection of persons who report regulatory infringements and the fight against corruption, which implements...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2024

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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

Mayer Brown

DOJ’s Criminal Division Updates Policy on 3 Key Topics: Artificial Intelligence, Whistleblower Programs, and Compliance Program...

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more

Thomas Fox - Compliance Evangelist

The 2024 ECCP: Complying with the 2024 ECCP on Whistleblowers

The Department of Justice (DOJ), in its 2024 Update, has explicitly directed companies to ensure they have robust processes in place to identify, manage, and mitigate emerging risks related to new technologies, including AI....more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Whistleblowers and Anti-Retaliation

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...more

Kohn, Kohn & Colapinto LLP

Emergency Congressional Action Needed to Save CFTC Whistleblower Program

In 2021, Congress passed an emergency measure to save the U.S. Commodity Futures Trading Commission (CFTC) Whistleblower Program from financial collapse. This measure is set to expire at the end of September, threatening to...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

The Volkov Law Group

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

The Volkov Law Group on

The increase in internal reporting comes at a critical time when government-sponsored whistleblower programs are maturing and expanding into new agencies.  The SEC’s program continues to increase and received a record number...more

The Volkov Law Group

DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II)

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The Securities and Exchange Commission has gained well-publicized traction through its formal whistleblower bounty program.  Only a small portion of these whistleblower reports involve FCPA, anti-bribery allegations. ...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

Bracewell LLP

Lifting the Fog on the Foreign Corrupt Practices Act: Enforcement and Compliance Trends to Watch in San Francisco

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As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more

Dentons

Ep. 2 - Why Anonymous Reporting is the Cornerstone of Your Compliance Program

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When was the last time your organization received an anonymous compliance concern?  Has it been so long you can’t recall? Maybe you consider yourself lucky that the organization has never received a concern on your watch, or...more

Jones Day

SDNY Launches Whistleblower Pilot Program to Encourage Self-Disclosure of Criminal Conduct

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The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions. ...more

A&O Shearman

Top challenges for white collar crime and investigations lawyers in 2024

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We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

Thomas Fox - Compliance Evangelist

How Triage and Investigations Can Drive a Culture of Speak Up

I recently concluded a podcast series with Case IQ. Over this series, I visited with Sharlyn Lauby, Jakub Ficner, Kenneth McCarthy, and Meric Bloch on the different facets of a great speak-up regime and how each of those...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Jones Day

FCPA 2021 Year In Review

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The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more

Jones Day

SEC Awards $28 Million+ to Whistleblower for Tip Relating to 2018 FCPA Settlements

Jones Day on

On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more

The Volkov Law Group

The EU Speaking Up Regime – Plenty of Process and Protection but no Bounties

The Volkov Law Group on

In 2019 the EU introduced new rules to enable whistleblowers to report about EU law irregularities (https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32019L1937), which EU countries must implement into their...more

Kohn, Kohn & Colapinto LLP

Congress Needs to Enact an Effective Ethics Agenda

Congress needs to implement an effective ethics agenda.  Important anti-corruption legislation has been sitting in various Senate and House committees awaiting action....more

Kilpatrick

COVID-19: Compliance Checklist for a Challenging Time

Kilpatrick on

The COVID-19 pandemic presents many unique challenges. With changing corporate strategies and priorities, companies should anticipate new or more prevalent legal and regulatory risks. The current climate creates the “perfect...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 6: Final Thoughts on the Scarlet ‘C’

Culture and Why It Matters - For anyone who was paying attention to the Astros, it has long been clear that the team had a very insular and toxic culture. The Astros culture was broken, toxic and this culture lead directly...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 5: The Whistleblower and The Amnesty

I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more

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