News & Analysis as of

Employees Corporate Misconduct

Thomas Fox - Compliance Evangelist

Addressing Pre-taliation

One of the most talked about subjects in corporate compliance is the issue of pre-taliation—an increasingly common enforcement target by the U.S. Securities and Exchange Commission (SEC). Matt Kelly and I did a recent podcast...more

Health Care Compliance Association (HCCA)

Beyond surveys: Rethinking traditional approaches to ethical culture assessments

To build a robust ethical culture, ethics and compliance professionals need effective culture assessments to pinpoint vulnerabilities and proactively address them. The U.S. Department of Justice’s (DOJ) update to the...more

Perkins Coie

DOJ Announces Whistleblower Awards Pilot Program and Introduces 120-Day Window for Corporate Self-Disclosures

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The U.S. Department of Justice (DOJ or the Department) announced its much-anticipated Corporate Whistleblower Awards Pilot Program on August 1, 2024. This three-year pilot will, for the first time outside of the False Claims...more

K&L Gates LLP

Department of Justice Launches First-Of-Its-Kind Corporate Whistleblower Awards Program

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After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....more

Mayer Brown

On the Rise: Employment Investigations

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WHAT IS AN EMPLOYMENT INVESTIGATION? Employment (or workplace) investigations can take many forms, and can be instigated by an employer, an employee or a third party; for example, investigations that form part of...more

Sheppard Mullin Richter & Hampton LLP

The Close-Out Debrief

Investigations are stressful for an organization’s leadership. But what is often overlooked is that they are stressful for an organization’s employees as well. The need-to-know nature of internal investigations usually...more

Kohn, Kohn & Colapinto LLP

SEC’s Record Sanction Against JP Morgan for Impeding Whistleblowing is a Major Step

On January 16, the U.S. Securities and Exchange Commission (SEC) announced a record $18 million sanction against JP Morgan for Rule 21F-17(a) violations, sending the strongest message yet that the SEC is cracking down on...more

Ankura

Non-Financial Misconduct: Will The Crispin Odey Case Reshape Investigations Into Behavioral Misconduct for the Financial Services...

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It has been a summer of revelations leaving the financial services sector facing uncertainty and increased scrutiny on how allegations of behavioral misconduct might be managed going forward. This came after multiple...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Focus on Corporate Enforcement Continues With Updated Policies Related to Corporate Crime and Compliance Programs

In early March 2023, the Department of Justice (DOJ) released several important updates to its policies related to corporate crime enforcement and compliance programs. We discuss below the following key topics: (i) The DOJ...more

The Volkov Law Group

NAVEX Issues 2022 Ethics Hotline Benchmarking Report: Whistleblower Reporting Rates and Retaliation Increase

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As the leading hotline provider in the global market, NAVEX is in the unique position of collecting and analyzing employee reporting trends.  Each year, NAVEX issues an important report on current trends in employee...more

Thomas Fox - Compliance Evangelist

Due Diligence, Zero Tolerance And Compliance

What is due diligence? What is zero tolerance? How do these impact employee morale? How do these concepts link together? I thought about these questions and several more when the Houston Astros announced they had traded for...more

Thomas Fox - Compliance Evangelist

The Damaging Myth of the Rogue Employee

As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives...more

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