Federal Pilot Programs

News & Analysis as of

Hallmark 5-Communications and Training

I. Training - The communication of your anti-corruption compliance program is something that must be done on a regular basis to ensure its effectiveness. The FCPA Guidance explains, “Compliance policies cannot work...more

OSHA Pilots New Expedited Whistleblower Process – Will Allow Complainants to Request Judicial Review

Seyfarth Synopsis: The DOL announced this week its new Whistleblower expedited Case review pilot process, to be conducted in its Region 9. Employers in this region may now anticipate even more cases going to the ALJ’s, and...more

OSHA Launches “Expedited Case Processing Pilot” For Whistleblower Claims

On August 1, 2016, the U.S. Department of Labor (DOL) launched a new pilot program, titled “Expedited Case Processing Pilot,” in its Western region. The program enables a complainant filing claims under whistleblower...more

Life in the Fast Lane: New OSHA Pilot Program Offers Expedited Review of Whistleblower Complaints

OSHA’s San Francisco region, which includes California, Nevada, and Arizona, launched a new pilot program on August 1, 2016 that would allow complainants, under certain circumstances, to ask OSHA to cease its investigation...more

Yates, Whistleblowers and FCPA Pilot Project: Re-Examining Your Internal investigation Protocols

Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies...more

The 100-Day Program at the ITC

In light of Audio Processing Hardware, it is now clear that, with respect to appeals of ITC 100-day program determinations, Commission determinations against a complainant are immediately appealable, while determinations in...more

Headlines from Mid-Year FCPA Enforcement Review

Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more

Top Ten International Anti-Corruption Developments for June 2016

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

The Power of a Justice Department Declination

Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination....more

Prevailing in an Era of Regulatory Enforcement – Balancing Risk and Compliance [Expect Focus – Vol. II, July 2016]

IN THE SPOTLIGHT - - SEC Sanctions Unregistered EB-5 Investments Broker SECURITIES - - FINRA to Assess Member Firms’ Culture - SEC Seeks Fund Responses to Distribution-In-Guise Guidance...more

Corporate Investigations and White Collar Defense - July 2016

“Official Acts”—What They Are… and Are Not - Why it matters: On June 27, 2016, the Supreme Court decided McDonnell v. U.S., holding that, for purposes of the federal public corruption statutes, an “official act”...more

Enforcement Week V: Three-Month Pilot Program Wrap Up

Today, I end my exploration of recent Foreign Corrupt Practices Act (FCPA) enforcement actions (and one UK Bribery Act enforcement issue), which have occurred since the enactment of the Department of Justice (DOJ) Pilot...more

DOJ’s FCPA Pilot Program Keeps Heat on Individuals

In April, the Department of Justice (DOJ) announced a one-year pilot program offering certain violators of the Foreign Corrupt Practices Act (FCPA) the possibility of reduced sanctions on top of any credit provided for by the...more

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more

White Collar Criminal Sentencing – What A Difference Cooperation Makes

The political campaign season has included plenty of discussion surrounding reforming our criminal justice system, and in particular sentencing for drug offenses. We have not heard much discussion about white-collar criminal...more

Enforcement Week I: Troubling Questions Raised in HSBC Prosecution

We had an interesting week of anti-corruption enforcement actions last week, both in the US and the UK. We have now had four Foreign Corrupt Practices Act (FCPA) enforcement actions since the announcement of the Depart Of...more

News of Note

Each week, Sheppard Mullin brings you News of Note in IP: The latest news in the IP-related fields of technology, privacy, fashion, advertising, music, and social media, curated by our IP team. Here are some of the stories...more

The First Ninety Days of the FCPA Unit’s Pilot Program

On April 5, 2016, the Department of Justice (“DOJ”) introduced a yearlong “Pilot Program” to guide the conduct of investigations and prosecutions pursuant to the Foreign Corrupt Practices Act (“FCPA”). Announced by Assistant...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

New Patent Office Initiative Provides a Boost to Cancer Immunotherapy Patent Applications

On June 29, 2016, the United States Patent and Trademark Office (USPTO) announced that it is implementing a pilot program to more quickly review patent applications related to treating cancer using immunotherapy. This...more

Edgartown's Muskeget tidal project faces questions

A municipal tidal power project proposed for the Massachusetts island of Martha's Vineyard faces federal deadlines if its licensing process is to continue. The Muskeget Channel Tidal Energy Project, proposed by the Town of...more

Battle of the Somme Week – Part II: Lessons for the CCO from Analogic

Today, I want to focus on the planning phase of the Battle of the Somme, which led to the disastrous casualties sustained by the British. Although rarely mentioned, I think the accidental drowning death of Lord Kitchener,...more

OSHA Announces New Enforcement Program for Whistleblower Cases

The “pilot” Severe Violator Enforcement Program will impose more stringent inspection procedures, enhanced settlement provisions, and “public scrutiny” for employers that OSHA deems to have engaged in “egregious behavior and...more

New OSHA Whistleblower ‘Shaming’ Program Draws Fire

The Occupational Safety and Health Administration has launched a pilot program in the Midwest region to shame employers who allegedly violate their employees’ whistleblower rights egregiously, but a critic contends the...more

Guidance on Effective Self-Disclosure of FCPA Violations for Life Sciences Companies

Every life sciences company with international operations should have a robust Foreign Corrupt Practices Act (FCPA) compliance program as part of its overall compliance strategy. On April 5, 2016, the Justice Department...more

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