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Internal Controls Whistleblowers

Ankura

Beyond Internal Controls: The Importance of Culture in “Failure to Prevent Fraud” Preparation

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The Failure to Prevent Fraud (FTPF) offence will officially come into force as part of the Economic Crime and Corporate Transparency Act in September 2025. In a previous article, we explored the government’s guidance around...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 12th - 13th, Polanco, CDMX, Mexico

Connect with the leading Anti-Corruption experts and discuss the latest compliance strategies at ACI’s Mexico Summit on Anti-Corruption & Compliance Programs. As Mexico’s longest running, premier anti-corruption and...more

Mitratech Holdings, Inc

Navigating International Whistleblower Protection Laws: Key Regulations Around the World

Foster better organizational transparency with insights into whistleblowing regulations and safeguards across the globe. Whistleblowers act as vigilant public advocates, exposing fraud and abuse. According to the...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

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In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

BCLP

DOJ Updates Criteria for Review of Corporate Compliance Programs, Emphasizing AI Issues

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On September 23, the Department of Justice updated the document it uses to evaluate a corporation’s compliance program in the context of wrongdoing by the corporation – the Evaluation of Corporate Compliance Programs, or...more

Holland & Knight LLP

DOJ Brings Suit Against University Under Its Civil Cyber-Fraud Initiative

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Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

Harris Beach Murtha PLLC

DOJ to Offer Whistleblowers Money to Combat Corporate Misconduct

U.S. Deputy Attorney General Lisa Monaco recently announced the Department of Justice (DOJ) is launching a new whistleblower monetary rewards program later this year and she expects it to drive investment in internal...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Morrison & Foerster LLP

Top 5 SEC Developments (November 2023)

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Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: • The SEC’s announcement of its Fiscal Year 2023 enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

Balancing Act: Sharing Information From an Internal Investigation Without Waiving Privilege

A whistleblower has triggered a race against time: An internal inquiry, directed by the audit committee and overseen by external counsel, has been launched in response to allegations that revenue was recorded without proper...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments - October 2023

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Eleventh Circuit Adopts “Totality of the Circumstances” Test for Showing Protected Activity Under SOX and Denies Whistleblower Petition for Review - In Ronnie v. Office Depot, LLC, --- F.4th ----, 2023 WL 6210623 (11th Cir....more

Thomas Fox - Compliance Evangelist

2023 Global Business Ethics Survey: Part 5-Workplace Ethics Concerns and the Need for Compliance

In a recent ECI podcast series , I had the opportunity to visit with Pat Harned, President of ECI. We took a deep dive into the 2023 Global Business Ethics Survey (GBES) revealed concerning trends in workplace ethics. The...more

Vinson & Elkins LLP

Bounty Hunters: SEC Pays Record Amount to Whistleblower

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On May 5, 2023, the Securities and Exchange Commission (“SEC”) issued an order (the “Order”)1 providing that it would pay a $279 million award to a whistleblower who assisted with the enforcement of an action by the SEC and...more

NAVEX

Hotline Benchmark Analysis – What a Deeper Analysis of 24 Issue Types Reveals

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Each year, NAVEX produces the Hotline & Incident Management Benchmark Report – a comprehensive assessment of trends in whistleblowing. This year, our analysis included 1.52 million reports across 3,430 organizations and is in...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more

Goodwin

Jury Acquits Tesla and Musk of Securities Fraud for 2018 Tweets Regarding Going Private

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On February 3, 2023, in the matter In re Tesla Inc. Securities Litigation, Case No. 3:18-cv-04865, a California federal jury cleared Tesla, Inc. (Tesla), and CEO Elon Musk of claims that they committed securities fraud,...more

BCLP

SEC penalizes company with good disclosures for insufficient controls

BCLP on

What happened? In a recent settlement order, the SEC charged Activision Blizzard with failing to maintain adequate disclosure controls and procedures. Notably, the SEC did not claim that the company’s SEC filings were...more

Society of Corporate Compliance and Ethics...

[Event] 11th Annual European Compliance & Ethics Institute - March 20th - 22nd, Amsterdam, Netherlands

In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more

Health Care Compliance Association (HCCA)

[Virtual Event] Boston Regional Healthcare Compliance Conference - September 9th, 8:25 am - 4:30 pm EDT

General and specialty compliance training from the comfort of your home or office! HCCA’s Regional Healthcare Compliance Conferences provide practitioners with virtual compliance training that includes updates on the...more

Hanzo

Financial Data Compliance and Enterprise Information Archiving

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When it comes to making sure financial data is safe and meets compliance regulations, understanding the different regulatory bodies and how they affect your organization is a vital first step. Two of the most common...more

Goodwin

2021 Year in Review: FCPA

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A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

K2 Integrity

Integrity Matters: Fraud Trends for 2022, Ep. 1

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This is part 1 of a special two-part series with Tom Fox and the Integrity Matters podcast discussing fraud issues and trends going forward into 2022. Olivia Allison shares strategies to proactively prevent fraud, focusing on...more

Farella Braun + Martel LLP

[Webinar] Investigations, Audits, Subpoenas, Oh My! - October 28th, 4:00 pm - 5:00 pm PT

Nonprofit entities can be just as prone to misconduct (theft, embezzlement, accounting snafus, executives’ HR violations) as corporations. While there is no foolproof formula to avoid internal crises entirely, knowing...more

Freeman Law

The False Claims Act: The Risks of Doing Business with the U.S. Government

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The False Claims Act (FCA) was passed by Congress during the Civil War to punish defense contractors for fraud. Under the FCA, a government contractor who submits fraudulent invoices or induces the government to grant a...more

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