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Disclosure Requirements Whistleblowers

Vinson & Elkins LLP

SEC Eliminates ESG Task Force

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Over the last few months, the U.S. Securities and Exchange Commission (“SEC”) discretely disbanded the Climate and ESG Taskforce (“ESG Task Force”) of its Division of Enforcement. The move follows a wave of recent pushback...more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

McCarter & English Blog: Government Contracts...

A New Frontier in Corporate Accountability: The DOJ’s Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more

Bracewell LLP

Creating an Army of In-House Investigators

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In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more

Carlton Fields

Expect Focus - Volume II, May 2024

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Last Lap in SEC RILA Rulemaking Critical Unresolved Issues - Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC...more

Eversheds Sutherland (US) LLP

More carrots, more sticks - DOJ announces agency-wide whistleblower pilot program

The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more

Bracewell LLP

The Race to Report: DOJ Announces Pilot Whistleblower Program

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In recent years, the Department of Justice (DOJ) has rolled out a significant and increasing number of carrots and sticks aimed at deterring and punishing white collar crime. Speaking at the American Bar Association White...more

A&O Shearman

Chief information Security Officers and cyber whistleblowing: considerations for boards and breach response teams

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At this point, it is self-evident that companies are grappling with an ever-evolving (think: tougher) cyber risk terrain. However, two recent cases against companies and their Chief Information Security Officers (CISOs),...more

Kohn, Kohn & Colapinto LLP

FinCEN’s New Rules for Reporting Beneficial Owners Create Opportunity for Whistleblowers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is enacting new rules for January 1, 2024, requiring companies to report their beneficial owners to FinCEN. Violations of these new...more

Burr & Forman

Hackers Extort Victim with SEC Whistleblower Complaint

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In an unintended consequence of the Securities and Exchange Commission's (SEC) unprecedented rulemaking agenda, a black-hat hacker gang has filed a whistleblower complaint against its victim for not reporting a cybersecurity...more

Kohn, Kohn & Colapinto LLP

Using Whistleblower Laws to Hold Polluters Accountable

Global political and business leaders have purported ambitious climate-focused goals for the decades ahead, such as eliminating landfill waste by 2030, transitioning to 100% renewable energy use by 2035, and achieving...more

Hogan Lovells

Key takeaways from the recent Hogan Lovells webinar on the rising risks of human capital disclosures

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With the rise of ESG-focused investing, public companies are increasingly making detailed statements about their workforce composition, DEI efforts, and social values. Those statements may reflect the company’s priorities,...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series | SEC Enforcement: Recent Trends and What to Expect - October 26th, 12:00 pm - 1:00 pm...

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As we enter the final quarter of 2023, the US Securities and Exchange Commission (SEC) continues to maintain an aggressive enforcement agenda. Looking ahead to 2024, companies should expect more of the same. In this webinar,...more

Saul Ewing LLP

Saul on ESG: Trends & Updates (October 2023)

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​This issue of Saul on ESG: Trends & Updates marks our first update tracking the legal trends and developments around environmental, social and governance (ESG). In recent years, we have been tracking and highlighting changes...more

Akin Gump Strauss Hauer & Feld LLP

Research Security: New NIH Policy Requires Foreign Subrecipients to Share Lab Notebooks & Research Data With the U.S. Prime...

On September 15, 2023, the National Institutes of Health (NIH) moved forward with a controversial new policy requiring foreign subrecipients to provide, at least once per year, copies of lab notebooks, data and documentation...more

Kohn, Kohn & Colapinto LLP

Gensler discusses markets “ripe with misconduct” and new SEC rules to address Changing Times

On September 12, the U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler testified before the U.S. Senate Committee on Banking, Housing, and Urban Affairs. His testimony emphasized that market growth combined...more

American Conference Institute (ACI)

[Event] 3rd Annual Summit on ESG - October 11th - 12th, New York, NY

Hosted by American Conference Institute, the 3rd Annual Summit on ESG returns for another exciting year with ESG professionals gathering to address key pillars and trends driving ESG in 2023. Attendees will gain insights...more

Rivkin Radler LLP

Tax Compliance: Self-Assessment, Transparency, and Enforcement

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NY’s Almost There- Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Sheppard Mullin Richter & Hampton LLP

California Supreme Court Adopts Broader Definition of “Disclosure” Under State Whistleblower Law

In People ex rel. Garcia-Brower v. Kolla’s, Inc., the California Supreme Court resolved a split between the Courts of Appeal for the First and Second Districts over whether a protected “disclosure” under Labor Code section...more

Foley & Lardner LLP

California High Court Defines Protected “Disclosure” Under Whistleblower Law

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In an employee-friendly opinion published Monday, May 22, 2023, the California Supreme Court held that an employee may be protected by the state’s whistleblower law, even when reporting unlawful activities that the employee...more

White & Case LLP

How to Avoid Risk of SEC Whistleblower Rule Violations in Connection with Employee-related Documents

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On February 3, 2023, the US Securities and Exchange Commission ("SEC") announced that a public company agreed to pay $35 million to settle charges of, among other things, violations of the whistleblower protection rule.1...more

Health Care Compliance Association (HCCA)

Report on Research Compliance Volume 20, Number 3. - Hunter College Whistleblower: Suit Was to End ‘Luxury Vacations, Fraud...

Report on Research Compliance Volume 20, Number 3. February 23, 2023 - To those who say whistleblowers are only interested in the money a settlement can bring, meet Devin English. An assistant professor in the Department of...more

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 11

SEC Announces Inspection Priorities for 2023 - On February 7, the Securities and Exchange Commission (SEC) announced its inspection priorities for the current year. The announcement began by noting that the SEC examined 15...more

Akin Gump Strauss Hauer & Feld LLP

The SEC Reminds Companies Not to Forget the ‘S’ in ESG: Activision Blizzard Reaches $35 Million Settlement Over Disclosure...

Key Points - On February 3, 2023, Activision Blizzard settled charges with the SEC, agreeing to pay $35 million to resolve novel claims that the company failed to maintain adequate disclosure controls to track workplace...more

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