Polsinelli Podcast - What Your Company Needs to Know About Whistleblower Claims
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action
Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
A Price Worth Paying?
SEC Whistleblower Program: What Employers Need to Know
Is Edward Snowden a Whistleblower?
First SEC whistleblower award-6 lessons learned
Whistleblower Tax Suits on the Rise
With so many articles available every month, it’s possible that a few got buried in either your inbox or the bowels of the blogosphere. Here are ten articles you don’t want to miss...more
In This Issue:
- A Summary Across Five Continents
- Law and Sanctions
- The Legislative Framework: Whistleblower Protections Across the Globe
- Global Differences: The Cultural...more
Financial service companies in the UK may soon face the prospect of remodelling their whistleblowing procedures and nominating whistleblowing champions.
The Public Interest Disclosure Act 1998 (PIDA) currently protects...more
Congress is required to enact secondary legislation to implement these reforms within one year.
On May 27, Mexican President Enrique Peña Nieto signed into law constitutional reforms (the Reforms) designed to strengthen...more
In this issue:
- FCPA AT A GLANCE
- THE ANTI-BRIBERY PROVISIONS OF THE FCPA
- TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY
- THE PAYMENT ELEMENT
- THE CORRUPT INTENT ELEMENT
- WHO IS A...more
On April 1, 2015, the Securities and Exchange Commission (SEC) announced that it had settled its first enforcement action under SEC Rule 21F-17, which prohibits companies from taking actions or using confidentiality...more
Much has been written about the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and its repeal of the Sustainable Growth Rate formula for physician compensation and the potential gainsharing safe harbor. But the...more
It’s an Absolute Privilege to Meet You! Texas Supreme Court Rules That Internal Investigation Report Provided by Shell Oil to DOJ Enjoys “Absolute Privilege” -
Why it matters: On May 15, 2015, the Texas Supreme Court...more
Compliance Issues With Private Equity Fund Managers Remains a Concern With the SEC - In May of last year, the SEC rang the alarm bells after conducting sweep examinations of private equity fund managers. At that time, the SEC...more
Continuing its emphasis on its Whistleblower Protection Program, the Occupational Safety and Health Administration (OSHA) released an updated Whistleblower Investigations Manual on May 21, 2015. OSHA enforces whistleblower...more
You can always count on lawyers to ring alarm belles and warn businesses. The line between accurate reporting and fear-mongering sometimes blurs when lawyers write so-called “alerts” to inform businesses of new or increasing...more
I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more
In keeping with past practice, federal agencies released their spring regulatory agendas on the eve of a holiday weekend. These semiannual reports list all of the federal agency regulations currently under development or...more
• Employers typically impose confidentiality restrictions to protect trade secrets and confidential information, including when conducting internal investigations and in employee separation...more
I conclude my three-part series based upon my podcast interview of noted white-collar defense lawyer and Foreign Corrupt Practices Act (FCPA) practitioner Mara Senn, a partner at Arnold & Porter LLP. In Part I, I considered...more
Discussion and Analysis -
Securities and investment advisory services offered through . . .
That phrase is ubiquitous among small and “independent” financial services firms, regularly appearing in 6-point or...more
In today’s post, I continue to explore my recent interview of Mara Senn, a partner at Arnold & Porter LLP in Washington DC. Senn is a white-collar practitioner who whose practice includes representing companies in...more
According to CEB, only 44% of employees who observed misconduct reported it, and only 13% of information about potential misconduct makes its way to the compliance function; that’s pretty scary since employees are key...more
In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more
Today we use King Arthur’s Round Table as the entry into our topic. The Round Table is the famous table around which he and his Knights congregated. Its shape implies that everyone who sits there has equal status. Wace, who...more
On April 22, 2015, the U.S. Securities and Exchange Commission (SEC) announced that it had awarded $1.4 million–$1.6 million to a compliance officer-turned-whistleblower who aided the SEC in an enforcement action against the...more
As the SEC takes aim at whistleblower “pretaliation” (attempts to muzzle whistleblowers via confidentiality and other employment agreements—overt or otherwise) ethics and compliance officers need to take practical steps to...more
I thought February was a jam-packed month for whistleblower-related news, but March had no shortage of whistleblower headlines. From the SEC kicking off the month with a hefty whistleblower award to OSHA issuing the final...more
The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges.
In this whitepaper, Andrew Foose, vice...more
A recent California court decision highlighted the importance of getting your facts straight before taking action against an employee. The ruling stemmed from a retaliation lawsuit brought by a woman whose former employer...more
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