News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Whistleblower Protection Policies Securities and Exchange Commission (SEC)

Skadden, Arps, Slate, Meagher & Flom LLP

Anti-Bribery and Corruption Risks Remain Despite FCPA Enforcement Pause

On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from Venice – Part 3: Straight from the Lion’s Mouth and Whistleblower Programs

In the final part of the Compliance Lessons from Venice series, we focus on one of Venice’s earliest tools for addressing misconduct: a reporting system predating modern whistleblower programs. Known as the Lion’s Mouth, this...more

Thomas Fox - Compliance Evangelist

DOJ Whistleblower Pilot Program: Transforming the Compliance Landscape

In a world where corporate integrity and accountability are more crucial than ever, the Department of Justice (DOJ) ‘s Whistleblower Pilot Program announcement marks a pivotal moment for compliance professionals. This...more

Davis Wright Tremaine LLP

CFTC Charges Trading Company With Market Manipulation and Whistleblower Protection Violations

On June 17, 2024, the CFTC's Division of Enforcement announced that it had reached a settlement with Trafigura Trading LLC ("Trafigura") over allegations that the firm manipulated oil derivatives prices while discouraging...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: March 1, 2024

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

Proskauer - Whistleblower Defense

DOJ Announces Development of a Pilot Whistleblower Rewards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (“DOJ”) is creating a pilot whistleblower rewards program, which will be developed and implemented over the next 90 days,...more

Mintz - Health Care Viewpoints

DOJ Announces it is Designing a Whistleblower Rewards Program

In early March 2024 at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco’s keynote remarks previewed the development of new and significant Department of...more

Parker Poe Adams & Bernstein LLP

New DOJ Whistleblower Program Is Reminder for Companies to Bolster Culture Around Reporting

The U.S. Department of Justice (DOJ) recently announced plans to roll out a new whistleblower program later this year following a 90-day development plan aimed at uncovering criminal conduct related to corporate wrongdoing....more

ArentFox Schiff

DOJ Continues Focus on Corporate Crime with New Whistleblower Program

ArentFox Schiff on

On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to...more

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

Troutman Pepper Locke

SEC Releases Fiscal Year 2023 Enforcement Results

Troutman Pepper Locke on

On November 14, the Securities and Exchange Commission (SEC) published its enforcement results for fiscal year 2023, which concluded on September 30. These results provide insight into the SEC's priorities and enforcement...more

Freiberger Haber LLP

Enforcement News: SEC Charges Investment Advisor With Violating Whistleblower Protection Rule

Freiberger Haber LLP on

We have often written about the SEC’s whistleblower program and, in particular, the success of the program with respect to detecting and preventing violations of the federal securities laws. The success of the program...more

StoneTurn

Whistleblower Day 2023: The (R)evolution of Speaking Up

StoneTurn on

On July 30, 1778, the Second Continental Congress passed the Whistleblower Protection Act of 1778, which is considered to be the first whistleblower law in world history. Much has changed in two and a half centuries, but very...more

Proskauer Rose LLP

Top 10 Whistleblowing and Retaliation Events of 2022

Proskauer Rose LLP on

2022 saw highly impactful whistleblower and retaliation events primarily resulting from an active U.S. Securities and Exchange Commission, an aggressive approach taken by the Occupational Safety and Health Administration, and...more

Proskauer - Whistleblower Defense

First Circuit: FCPA is not a “Rule or Regulation of the SEC” Under SOX Whistleblower Provision

On July 13, 2022, the First Circuit reversed a denial of summary judgment, finding plaintiff could not satisfy his burden of showing he engaged in protected activity under the SOX whistleblower protection provision. Baker v....more

Guidepost Solutions LLC

With Enforcement Actions Likely to Increase in 2022, Companies Should Ask Where the Bodies are Buried

In 2022, companies are likely to see an increase in white collar and regulatory investigations and enforcement actions. Here are just a few reasons why this is likely to happen. First, in the late fall, Deputy Attorney...more

Akin Gump Strauss Hauer & Feld LLP

The FCA And SEC Annual Reports – A Statistical Comparison

Key Points - The SEC and the FCA each publish annual reports on their enforcement actions. Whilst enforcement data only shows a snapshot of the regulators’ activities, there is much to be learned from these reports,...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

The Impact of International Whistleblowing on Global Corporate Compliance

This is the first part of a two-part article. Over the last 33 years, whistleblowers have enjoyed historic success advancing claims under the United States’ False Claims Act (FCA). The United States government has recovered...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments - April 2019

Foley & Lardner LLP on

Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: Fifth...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for February 2018

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - February 2018

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Thomas Fox - Compliance Evangelist

Day 7 of One Month to Better Investigations and Report-How Investigations Inform Remediation

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior management attention to the...more

Foley & Lardner LLP

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

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