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NAVEX Global’s Most Popular Ethics & Compliance Matters Articles from 2014

This year, we relaunched our blog with the goal of better serving the ethics and compliance community, providing deeper insights on topics that matter most to E&C professionals, as well as best practices and practical steps...more

JD Supra's Popular Whistleblower Reads for 2014

A year-end recap of some of the most popular Whistleblower articles on JD Supra in 2014. Stay good!...more

Changing Regulatory Regime Necessitates New Solutions To An Old Problem: 5 Elements Critical To An Anti-Fraud Compliance Program

US government regulators have become more aggressive in their detection and enforcement of fraud against the government. One of the key tools they are using to combat such fraud is the False Claims Act. Most FCA cases are...more

When the Whistle Blows, What Follows?

Real estate investment trust American Realty Capital Properties (“ARCP”) recently announced the preliminary findings of an Audit Committee investigation into accounting irregularities and the resulting resignation of its...more

Got DBE Fraud Skeletons?

Every Halloween, the cute traditional images re-emerge from our closets and the attics. Ghosts, gravestones, plastic pumpkins, and perhaps the most common of all – skeletons. Given the recent heightened status of...more

False Claims Act Does Not Protect An Employee Disclosing His Whistleblower History

On October 20, the United States District Court for the Southern District of Ohio found that the False Claims Act (“FCA”) did not protect an employee who was fired after revealing his history as a whistleblower and offering...more

Third Circuit Tightens “Original Source” Requirement for Whistleblowers

Back in 2003 Karl Schumann filed a whistleblower suit alleging that as an executive with benefits company Medco, he learned that Bristol-Myers Squibb and AstraZeneca paid kickbacks to Medco to buy and recommend brand name...more

FINRA Issues Guidance Notice To Warn Against Settlements Barring Whistleblower Tips

This month, FINRA issued guidance notice 14-40 to reminds firms that “it is a violation of FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) to include confidentiality provisions in settlement agreements...more

FINRA Again Cautions Against Confidentiality Provisions Silencing Whistleblowers

As reported this week by Law360 (subscription required), the Financial Industry Regulatory Authority (FINRA) recently issued a reminder (Regulatory Notice 14-40) warning firms against the use of confidentiality provisions in...more

A Review of Recent Whistleblower Developments

On July 31, 2014, the SEC awarded $400,000 to a whistleblower who had reported internally before providing information to the SEC. The award was unique because the SEC’s Claims Review Staff had denied the whistleblower’s...more

SEC gives first whistleblower award to audit and compliance employee

The Securities and Exchange Commission has underscored the importance of a timely response to internal reports of wrongdoing by awarding $300,000 to a whistleblower who was an audit and compliance employee....more

2014 Corporate Governance and Compliance Hotline Benchmarking Report Preview: Benchmarking the Health of Your Whistleblower...

It’s that time again! Last week we released the 2014 Corporate Governance and Compliance Hotline Benchmarking Report. This is our 9th year releasing the Benchmarking Report. The full report covers best practices across all...more

Employment Flash - September 2014

In This Issue: - SEC Pays First Whistleblower Award to Audit and Compliance Professional - Supreme Court Allows Affordable Care Act Contraceptives Religious Exemption - EEOC Adopts New Pregnancy...more

SEC Puts Their Money Where Their Mouth Is: $30 Million Awarded to Whistleblower

On September 22, 2014, the SEC announced its largest whistleblower award to date under its Dodd-Frank whistleblower bounty program. It awarded $30-$35 million to an anonymous whistleblower who the Commission said provided...more

Think High Stakes Whistleblowing is Just a U.S. Phenomenon? Think Again.

Today the SEC announced that it will pay $30 million to a whistleblower in the largest award ever doled out by the agency. This news is monumental and will send shock waves around the financial world—along with gut...more

Two Whistleblower Cases Show Major Contrast of How Cases Can Result

A couple of recent whistleblower cases that have received national attention show the large divide that still exists in the way that these cases can progress. The first case saw the SEC award a whistleblower $400,000 for...more

Larger Rewards For Wall Street Whistleblowers May Be On The Horizon

As reported by the Wall Street Journal, the Obama administration will seek to remove the $1.6 million cap on rewards to whistleblowers who provide evidence of criminal conduct by financial executives under the 1989 Financial...more

SEC Awards $300,000 to an Audit & Compliance Professional for Whistleblowing: Key Implications & Lessons Learned

Last week, the SEC announced its first whistleblower award to an audit and compliance professional. The $300,000 award announcement noted that the recipient had “reported concerns to appropriate personnel within the company,...more

Federal Court in District of Columbia Dismisses Whistleblower Claims of Former Fannie Mae Employee

On August 25, 2014, the District Court for the District of Columbia dismissed a claim brought by a former employee of Fannie Mae alleging violations of the anti-retaliation provisions of the Sarbanes-Oxley Act and the...more

Court of Appeals asked to clarify scope of Dodd-Frank Act whistleblower protections

A federal court of appeals has been asked to clarify the scope of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010’s (“Dodd-Frank” or “Act”) whistleblower protections. Specifically, the court has been...more

Are More SEC Protections on the Way for Whistleblowers?

A pro-whistleblower coalition comprising organizations including the Government Accountability Project, the Project on Government Oversight and more is in the news for pressuring the Securities and Exchange Commission (SEC)...more

Happy Birthday Dodd-Frank: The Whistleblower Program Milestones and How They’ve Impacted Business Ethics Training

Did you have some cake? Break out the balloons? While it’s hard to believe, it is true. Our little Dodd-Frank, signed into law by President Obama in 2010, is already four years old and about ready for pre-school. Although we...more

What’s Happening with Whistleblowing?

This summer the SEC and the Wall Street Journal have reported several noteworthy items concerning the SEC’s whistleblower program, one of the most controversial components of the Dodd-Frank Act of 2010....more

What’s Scarier than a Compliance Officer Turned Whistleblower? A Whole Association of Them

In U.S. ex rel. Corporate Compliance Assocs. v. N.Y. Society for the Relief of the Ruptured & Crippled the court ruled that the whistleblower failed to meet the False Claims Act’s requirement that allegations be described...more

Civil War Era Is ‘Gone With The Wind’ Causing Companies To Question Need For FCA, Whistleblower Hotline Providers…

The Civil War era is my favorite part of American history. Every summer, my father would take my sister and me on “educational” vacations and when I was nine we went to Gettysburg. I’m not altogether sure if it’s the...more

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