News & Analysis as of

Upjohn Warnings Compliance

The Volkov Law Group

How to Audit Your Internal Investigation Program (Part II of III)

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As an initial step, an audit of an internal investigation program requires a detailed understanding of the operation of a company’s internal investigation program. ...more

Saul Ewing Arnstein & Lehr LLP

D.C. Circuit Once Again Upholds Privilege Over Internal Investigation Documents

In United States ex rel. Barko v. Halliburton Co. et al., a qui tam suit we previously covered, the District of Columbia Circuit Court of Appeals once again ruled that defense contractor KBR Inc.’s internal investigation...more

Baker Donelson

Department of Justice Mandate: Prosecute Individuals for Corporate Wrongdoing

Baker Donelson on

On September 9, 2015, Sally Quillian Yates, the Deputy Attorney General of the U.S. Department of Justice (DOJ), issued a directive to the leaders of the divisions of the DOJ and to U.S. Attorneys to combat corporate fraud by...more

Alston & Bird

“Individual Accountability for Corporate Wrongdoing”: The Yates Memo and the DOJ’s Focus on Individuals

Alston & Bird on

On September 9, 2015, the Department of Justice issued a memo (“Individual Accountability for Corporate Wrongdoing”) to federal prosecutors nationwide implementing new policies that—for the first time—prioritize the...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments

Foley & Lardner LLP on

SEC Awards Another Whistleblowing Compliance Officer - On April 22, 2015, the Securities and Exchange Commission (SEC) announced an award between $1.4 and $1.6 million to a compliance officer who provided information...more

Morrison & Foerster LLP

Upjohn Upheld: D.C. Circuit Re-Affirms Privilege Protections for Multi-Purpose Internal Investigations

In one of the most important decisions of the year for corporate legal departments, on June 27, the D.C. Circuit held that a company’s internal investigation documents were protected by the attorney-client privilege where...more

Snell & Wilmer

Common Sense Prevails as D.C. Circuit Applies Upjohn in Vacating District Court Order to Produce Investigation Reports

Snell & Wilmer on

Government contractors and other companies subject to internal investigation requirements won some relief from the United States Court of Appeals for the D.C. Circuit on June 26 with a decision that firmly reiterated that...more

JD Supra Perspectives

D.C. Appeals Court Upholds Privilege For Internal Investigation Preceding False Claims Act Litigation

JD Supra Perspectives on

The KBR decision should not be interpreted as a sign that internal investigations of regulatory compliance are privileged per se. Companies should keep the following principles in mind when conducting any internal...more

Thomas Fox - Compliance Evangelist

What is Your FCPA Investigation Protocol?

On Wednesday, at the ACI FCPA Bootcamp, there was an excellent presentation by Jay Martin, Vice President, Chief Compliance Officer (CCO) and the Senior Deputy Counsel for Baker Hughes Incorporated and Jacki Trevino, Senior...more

The Volkov Law Group

Internal Investigations And Interviews (Part III of IV)

The Volkov Law Group on

Interviews are the critical part of every internal investigation. Before conducting any interviews, it is important for the investigator to know as much as possible about the events under investigation. Such knowledge can...more

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