On January 7, 2019, the New York State Department of Financial Services (the “Department”) published Guidance on Whistleblowing Programs (the “Guidance”). ...more
The recent leak of an internal U.S. Department of Justice (DOJ or Department) memorandum setting forth considerations for dismissal of civil cases brought under the False Claims Act (FCA) offers helpful guidance not only to...more
Today being the fortieth anniversary of the December 19, 1977 enactment of the Foreign Corrupt Practices Act (“FCPA”), we offer this Client Alert in celebration of the occasion. Fittingly, the U.S. Department of Justice...more
12/20/2017
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure
Just in time for the holiday season, the U.S. Securities and Exchange Commission (“SEC” or “Commission”) has brought joyful news to three whistleblowers who will receive substantial awards of over $8 million each to two...more
As we have previously noted here, in Digital Realty Trust, Inc. v. Somers, the United States Supreme Court will decide how to interpret the term “whistleblower” under the Dodd-Frank Act, and how to apply the term to the Act’s...more
Who is a “whistleblower” entitled to protection under the anti-retaliation provisions of the Dodd-Frank Act (the “Act”)? In Digital Realty Trust, Inc. v. Somers, the United States Supreme Court will answer that question by...more
11/24/2017
/ Anti-Retaliation Provisions ,
Corporate Counsel ,
Digital Realty Trust Inc v Somers ,
Dodd-Frank ,
Hiring & Firing ,
Internal Reporting ,
Sarbanes-Oxley ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Whistleblower Protection Policies ,
Whistleblowers ,
Wrongful Termination
In United States v. Luce, the U.S. Court of Appeals for the Seventh Circuit recently held that a plaintiff suing under the False Claims Act (“FCA”), 31 U.S.C. § 3729 et seq., must demonstrate not merely that the government...more