News & Analysis as of

Voluntary Disclosure Self-Reporting

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

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

Farella Braun + Martel LLP

New DOJ Corporate Whistleblower Awards Program Pits Company Compliance Programs Against the Clock

The Department of Justice announced a Corporate Whistleblower Awards Pilot Program on August 1, 2024. If a whistleblower voluntarily reports original, truthful, and complete information to DOJ in a relevant subject...more

Hogan Lovells

U.S. announces export enforcement and compliance resources for academic research institutions

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The U.S. Department of Commerce’s Bureau of Industry and Security has published a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources targeted to the academic community. The...more

Bradley Arant Boult Cummings LLP

DOJ Implements New Whistleblower Reward Program

Companies who submit healthcare claims to private payors, provide financial services to customers, interact with domestic or foreign public officials, or otherwise operate in highly regulated industries should take note that...more

Epstein Becker & Green

DOJ Launches the Corporate Whistleblower Awards Pilot Program

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On August 1, 2024, the Department of Justice (“DOJ”) launched the Corporate Whistleblower Awards Pilot Program (“Pilot Program”), a three-year initiative managed by the Criminal Division’s Money Laundering and Asset Recover...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

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

Perkins Coie

DOJ Announces Whistleblower Awards Pilot Program and Introduces 120-Day Window for Corporate Self-Disclosures

Perkins Coie on

The U.S. Department of Justice (DOJ or the Department) announced its much-anticipated Corporate Whistleblower Awards Pilot Program on August 1, 2024. This three-year pilot will, for the first time outside of the False Claims...more

K&L Gates LLP

Department of Justice Launches First-Of-Its-Kind Corporate Whistleblower Awards Program

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After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....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

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

Fisher Phillips

DOJ’s New Whistleblower Program Will Lead More Employees to Report Corporate Misconduct: How It Works and 6 Steps You Should Take...

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Employees will be more incentivized than ever to report corporate misconduct to the Department of Justice thanks to a recently rolled-out initiative. After previously introducing whistleblower programs that reward companies...more

Fisher Phillips

Feds Encourage Companies to Come Clean on Criminal Conduct and Reward Whistleblowers for Reporting Wrongdoing: Key Takeaways for...

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Federal prosecutors are exploring new ways to encourage business leaders to invest in their corporate compliance programs. Indeed, a Department of Justice official recently announced several new programs incentivizing...more

Mintz - Health Care Viewpoints

DOJ Announces it is Designing a Whistleblower Rewards Program

In early March 2024 at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco’s keynote remarks previewed the development of new and significant Department of...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

Thomas Fox - Compliance Evangelist

Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure

In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving...more

Vinson & Elkins LLP

“Call Us Before We Call You”: SDNY Creates New Individual Self-Disclosure Program

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On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

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Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Insights: Enforcement and Litigation

Expert Allegations Could Become More Frequent in Securities Fraud Complaints and Possibly Erode Pleading Standards - A Ninth Circuit panel ruling that plaintiffs could use expert analysis to bolster securities fraud claims...more

WilmerHale

OFSI Encourages Self-Reporting of Sanctions Breaches

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Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

K&L Gates LLP

Recent Settlements Provide Insight on the SEC's Approach to Self-Reporting and Cooperation Credit in Enforcement Actions

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Introduction - A perennial message from the Securities and Exchange Commission (SEC) Division of Enforcement is to extol the benefits of cooperation with enforcement investigations. The link between cooperation and a...more

A&O Shearman

DOJ Announces Safe Harbor For Companies That Self-Disclose Misconduct Discovered During M&A

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On October 4, 2023, Deputy Attorney General Lisa O. Monaco announced a Department of Justice-wide safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions.  During her remarks at the...more

Alston & Bird

The Clock Is Ticking: DOJ Announces New, Department-Wide Mergers & Acquisitions Safe Harbor Policy

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Our White Collar, Government & Internal Investigations and Mergers & Acquisitions Teams explain how acquiring companies can find a limited safe harbor from enforcement when they find pre-merger misconduct....more

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