News & Analysis as of

Policies and Procedures Enforcement Actions Whistleblowers

Perkins Coie

DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, &...

Perkins Coie on

On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more

NAVEX

The Increasing Importance – and Visibility – of Internal Investigations 

NAVEX on

New DOJ whistleblower incentives. Investigation-related KPIs. Accountability demands from stakeholders of all stripes.    A combination of hard work by ethics and compliance professionals, high profile internal system...more

Hogan Lovells

Whistle While You Work: Are You Ready for the ADGM’s New Protection Regulations?

Hogan Lovells on

On 5 July 2024, the Abu Dhabi Global Market (ADGM) brought into force enhanced protections for whistleblowers. Under the Whistleblower Protection Regulations 2024 (the “Protection Regulations”), ADGM employers must implement...more

Akin Gump Strauss Hauer & Feld LLP

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more

Holland & Knight LLP

SEC Settlements Over Whistleblower Protections Pile Up

Holland & Knight LLP on

As the SEC closed its fiscal year, it filed three separate enforcement actions against companies for purported violations of Rule 21F-17 under the Securities and Exchange Act of 1934, which prohibits persons from impeding...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

Jones Day

SEC Approves Amendments to Whistleblower Program Rules and Issues Interpretive Guidance

Jones Day on

Companies should consider review of their compliance programs and procedures for addressing internal complaints or tips of potential misconduct. On September 23, 2020, the Securities and Exchange Commission ("SEC") adopted...more

Jones Day

A New Frontier for Whistleblowers: The Model Whistleblower Award and Protection Act for the States

Jones Day on

New efforts by states to incentivize whistleblowers financially underscore the importance of comprehensive corporate compliance programs that effectively address all internal reports of potential misconduct that may...more

Jones Day

SEC Announces Five Whistleblower Awards Totaling $54 Million Since April 1, 2020

Jones Day on

The Situation: The Securities and Exchange Commission ("SEC") has announced a string of substantial whistleblower awards totaling $54 million since April 1, 2020. The Result: The financial incentives for employees or third...more

American Conference Institute (ACI)

[Event] 36th International Conference on the Foreign Corrupt Practices Act - December 4th - 5th, Washington, DC

The full agenda for ACI's 36th International Conference on the Foreign Corrupt Practices Act this December is now available. See why this event stands apart as the annual gathering for the worldwide anti-corruption...more

Fenwick & West LLP

SEC Imposes $1.75 Million Penalty Against Issuer for Using Wrong Standard for Disclosing Executive Perquisites

Fenwick & West LLP on

The U.S. Securities and Exchange Commission announced on July 2, 2018, that The Dow Chemical Company had agreed to a cease and desist order and to pay a $1.75 million penalty for failing to disclose certain expenses as...more

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