Compliance into the Weeds: A Deep Dive into Employee Leaks and Corporate Culture
The EU Whistleblowing Directive
Six Steps Companies Can Take to Manage the Risk of Using Generative AI
Helpline Usage (or Lack Thereof)
Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean
Encouraging Internal Whistleblowers
Encouraging Employee Feedback and Internal Whistleblowing
Integrity Matters: Fraud Trends for 2022, Ep. 1
JONES DAY TALKS®: The eBay Cyberstalking Case: Mitigating the Compliance Risks of Employee Misconduct
Doing Business in the European Union | Reporting Systems and the Importance of Culture & Language
Doing Business in the European Union | EU Directive, Following Up With The Whistleblower
Susan Roberts on Creating a Compliance Program Book
Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting
Those of us in compliance and whistleblower programs have been eagerly awaiting the release of the SEC Office of the Whistleblower (OWB) report, and on November 21st, we were able to view the highly anticipated recap (dated...more
On November 13, 2024, the United States Supreme Court heard oral argument in an appeal from a decision of the United States Court of Appeals for the Ninth Circuit in a putative class action asserting claims under the...more
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
DOJ Launches Corporate Whistleblower Awards Pilot Program - On August 1, the US Department of Justice (DOJ) announced the details of its new Corporate Whistleblower Awards Pilot Program. According to the DOJ, the...more
Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more
The U.S. Securities and Exchange Commission’s (SEC) Whistleblower Program was created in Section 922 of the Dodd-Frank Act of 2010, which amended the Securities Exchange Act to include a whistleblower provision. It has since...more
Background - Under Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, Congress expanded protections for whistleblowers reporting possible violations of federal securities laws to the...more
On November 14, 2023 the Securities and Exchange Commission (SEC) released its annual Office of the Whistleblower Report to Congress for fiscal year 2023 (October 1, 2022-September 30, 2023). This report highlighted several...more
In Short - The Background: On October 10, 2023, the U.S. Securities and Exchange Commission (the "SEC") adopted amendments to the rules that govern beneficial ownership reporting for investors, marking the first update to...more
The Securities and Exchange Commission (SEC) just announced a settled enforcement matter involving a public company and its CFO. (AP File No. 3-21438) The case presents three important takeaways for companies and...more
Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more
In testimony before Congress earlier this year, U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler reported that the SEC received 46,000 complaints, tips, and/or referrals in fiscal year 2021, which nearly...more
Now, nearly 20 years after Congress passed the Sarbanes-Oxley Act, the congressional mandate to promulgate and enforce rules for corporate attorneys has gone largely unfulfilled. But all that may change. A recent speech by...more
On February 10, 2022, the U.S. Securities and Exchange Commission announced two proposed amendments to its whistleblower program rules. As we previously reported, a closely divided SEC adopted a final rule implementing...more
2021 was another blockbuster year in the whistleblowing and retaliation arena. The U.S. Securities and Exchange Commission Office of the Whistleblower has now issued in excess of $1 billion in whistleblower bounties. ...more
On November 15th, the Securities and Exchange Commission (SEC) Office of the Whistleblower (OWB) released its 2021 Annual Report to Congress that reports staggering statistics for FY 2021 and should sound warning bells for...more
On June 28, 2021, the United States District Court for the Northern District of California granted the Company’s Rule 12(b)(6) motion to dismiss after an executive claimed he was discharged in violation of the Dodd-Frank...more
On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more
SEC Whistleblower Awards to 40 individuals in 2021 surpass total awards in fiscal year 2020. On March 29, 2021, the Securities and Exchange Commission ("SEC") announced an award of more than $500,000 to a whistleblower who...more
In 2021, whistleblowers will come into their own in ways previously unseen. While the United States has had whistleblower protections for two decades, Europe and the Asia-Pacific region are setting new standards in...more
A recent Bloomberg article reports that whistleblower complaints to the SEC have soared as employees have been working from home during the COVID-19 pandemic. According to the article, the SEC received 6,900 complaints in...more
Despite the program's success, there remains considerable room for public companies and SEC registrants to improve their internal reporting apparatus—to build cultures that encourage whistleblowers to report internally...more
On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more
This year is proving to be a record-setting year for whistleblowers. On October 22, the U.S. Securities and Exchange Commission announced it had awarded an unprecedented $114 million to a whistleblower who, the SEC says,...more