News & Analysis as of

Securities and Exchange Commission (SEC) Voluntary Disclosure

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

Sheppard Mullin Richter & Hampton LLP

Latest Round of SEC “Off-Channel” Communications Settlements Highlights Risks for Investment Advisers and Benefits of...

More than two years after announcing the first round of settlements in the ongoing “off-channel communications” probe, the SEC recently announced another round of settlements with 26 financial firms, totaling $390 million in...more

Foley & Lardner LLP

Understanding the Risk vs. Reward of Department of Justice’s Corporate Criminal Whistleblower Awards Pilot

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The Securities & Exchange Commission, the Department of Health & Human Services, and other agencies have long had established bounty programs that reward successful tipsters. On August 1, 2024, the Department of Justice’s...more

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

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In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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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

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

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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

BakerHostetler

DOJ Corporate Whistleblower Awards Pilot Program

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DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more

Womble Bond Dickinson

DOJ Debuts Pilot Corporate Whistleblower Awards Program

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The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more

Dorsey & Whitney LLP

DOJ’s New Whistleblower Program Incentivizes Individuals and Corporations to Disclose Wrongdoing

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The U.S. Department of Justice (DOJ) just launched the new corporate whistleblower awards pilot program that it previewed this past March. ...more

Venable LLP

DOJ Criminal Division Launches New Corporate Whistleblower Award Program

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced the Department of Justice (DOJ) would release a new whistleblower rewards program for civil and criminal forfeitures. On August 1, 2024, DOJ did just that—as the...more

Latham & Watkins LLP

DOJ Launches New Whistleblower Incentive Program

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DOJ’s pilot program aims to fill gaps in existing federal whistleblower programs and incentivize prompt corporate self-disclosure alongside individual whistleblower tips. Following the March 2024 announcement of its...more

WilmerHale

DOJ Rolls Out Corporate Whistleblower Pilot Program

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On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

Morrison & Foerster LLP

Corporate Whistleblower Awards Pilot Program

On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more

Cranfill Sumner LLP

DOJ’s Corporate Whistleblower Awards Pilot Program Is Open for Business

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On August 1, 2024, the United States Department of Justice’s (DOJ) Criminal Division announced the details of its much-anticipated Corporate Whistleblower Awards Pilot Program. This program is designed to incentivize...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

McDermott Will & Emery

DOJ Unveils Details of Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more

KPMG Board Leadership Center (BLC)

Learning by proxy - Highlights and trends from the 2024 proxy season

Both investors and companies are maturing in how they view critical issues raised at the corporate ballot box. Even amid a proxy season that included “the priciest shareholder fight ever,” according to The Wall Street...more

K&L Gates LLP

Federal Agencies Have Placed a Heightened Priority on Whistleblowers and Speedy Cooperation

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As new areas of the law emerge, driven in part by technology and the free flow of information, federal agencies are becoming more aggressive with a tried and true carrot-and-stick approach to law and regulatory enforcement. ...more

Akin Gump Strauss Hauer & Feld LLP

SEC Publishes Five C&DIs Covering Cybersecurity Incident Disclosures Pursuant to Item 1.05 of Form 8-K

On June 24, 2024, the U.S. Securities and Exchange Commission (SEC) published five new Form 8-K Compliance and Disclosure Interpretations (C&DIs) expanding the agency’s interpretations of cybersecurity incident disclosures...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Issues New Statement on Cybersecurity Incident Disclosure

Last week, Erik Gerding, Director of the SEC’s Division of Corporation Finance (the Division), issued a statement providing clarification regarding the disclosure of cybersecurity incidents by reporting companies. This...more

Davis Wright Tremaine LLP

SEC Clarifies Reporting of Material vs. Immaterial Cybersecurity Incidents

The U.S. Securities and Exchange Commission's (SEC) Division of Corporate Finance (Division) published a statement on May 21, 2024, regarding how public companies may disclose cyber incidents they determined to be immaterial....more

A&O Shearman

New SEC guidance on cybersecurity incident disclosures

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The Director of the Division of Corporation Finance of the SEC issued a statement last week relating to the recent SEC cybersecurity disclosure rules that require public companies to disclose the occurrence of material...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

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Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

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