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Whistleblower Awards

Kohn, Kohn & Colapinto LLP

Landmark UK Report Details Effectiveness of Whistleblower Awards

Whistleblower awards are empirically proven to strengthen the fight against financial crime, according to a report released on December 10 from the Royal United Services Institute (RUSI). The report builds upon a growing...more

Moore & Van Allen PLLC

THE DESK: MVA’s Swaps and Derivatives Newsletter - December 2024

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With the CFTC still in the early stages of its fiscal year, in the month of November, we did not see a lot of action by way of publicly-released enforcement actions from the CFTC or enforcement-related public statements from...more

Kohn, Kohn & Colapinto LLP

Adani FCPA Charges Show Scope of U.S. Laws for Indian Whistleblowers

On November 20, the U.S. Securities and Exchange Commission (“SEC”) and Department of Justice (“DOJ”) announced parallel charges against Indian billionaire Gautam Adani, his nephew Sagar Adani, business associate Cyril...more

Mitratech Holdings, Inc

Turning the SEC Enforcement Results into Opportunity: Historic Penalties Signal a Compliance Shift

The SEC’s fiscal year 2024 enforcement results signal a pivotal moment for U.S. capital markets. Despite a 26% decline in the total number of enforcement actions compared to 2023 (sitting at a total of 583 for this year), the...more

Foodman CPAs & Advisors

IRS Whistleblower Program Scores Big Win

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The IRS Whistleblower Program helps boost the “fair and effective enforcement of our nation’s tax laws and the success of our voluntary tax system.” The IRS Whistleblower Program is dependent on people who become aware of tax...more

Kohn, Kohn & Colapinto LLP

Utilizing the SEC Whistleblower Program to Hold Private Equity Owners of Nursing Homes Accountable

Government authorities and whistleblowers can receive ‘pennies on the dollar’ in penalties against nursing home chains defrauding vulnerable elderly patients. To improve recovery amounts, whistleblowers should consider...more

Cozen O'Connor

Whistleblower Watch - A quarterly update on FCA Enforcement and Qui Tam Litigation

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Whistleblower Watch is a critical resource for in-house counsel and compliance professionals. Each quarter, Cozen O’Connor summarizes the most notable False Claims Act (FCA) enforcement actions, settlements, and legal trends,...more

Kohn, Kohn & Colapinto LLP

Honest Corporate Disclosure Dims Under New DOJ Evaluation of Corporate Compliance Programs

In September 2024, the U.S. Department of Justice (DOJ) published an updated Evaluation of Corporate Compliance Programs to provide a roadmap for companies on how to run their internal compliance to avoid prosecution,...more

A&O Shearman

CFTC Awards $4 Million To Whistleblowers, Citing Disclosure Timing

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On November 12, 2024, the Commodity Futures Trading Commission (“CFTC”) awarded nearly $4 million to two whistleblowers who provided information leading to a successful enforcement action. In awarding the sum, the CFTC...more

Parker Poe Adams & Bernstein LLP

What DOJ's Latest Guidance on Artificial Intelligence Corporate Compliance Means for Businesses

The U.S. Department of Justice (DOJ) recently updated its Evaluation of Corporate Compliance Programs (ECCP), which prosecutors consider when investigating, charging, and negotiating plea or other agreements with...more

Kohn, Kohn & Colapinto LLP

Whistleblowers are Key to CFTC’s Priority of Combating Voluntary Carbon Market Fraud

Voluntary Carbon Markets (“VCMs”) are touted as a promising solution to rising global carbon emissions. They have the potential to strengthen climate technology and promote projects that reduce carbon dioxide emissions and...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments – Q3 2024

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On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more

Kohn, Kohn & Colapinto LLP

U.S. Attorney Office “Whistleblower” Programs Sow Confusion and Pose Risks to Corporate Whistleblowers

In recent weeks, a number of U.S. Attorneys’ Offices (USAOs) across the country have rolled out “Whistleblower Pilot Programs” offering the potential of non-prosecution agreements in exchange for voluntary self-disclosure of...more

Fisher Phillips

The Whistleblowing Just Got Louder: 8 Things Employers Should Do in Response to Feds’ New Whistleblower Awards Program

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A new initiative rolled out by federal officials this summer can reward corporate whistleblowers with up to $30 million – which means it is incumbent upon your organization to step up your game when it comes to corporate...more

Stevens & Lee

After the Whistle: Constitutional Challenges to Qui Tam Actions

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Whenever there is a pot of money up for grabs, people will inevitably want more than their fair share. And when that money is doled out through government contracts, opportunities for fraud abound. The government can...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

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In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

Paul Hastings LLP

DOJ Criminal Division Issues Updated Guidance on Corporate Compliance Programs Focused on AI Risks

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On September 23, 2024, the Department of Justice’s (“DOJ”) Criminal Division announced significant changes to its Evaluation of Corporate Compliance Programs (“ECCP”), which prosecutors use in assessing the effectiveness of...more

Woods Rogers

The Truth Shall Set You Free: Western District of Virginia Unveils Whistleblower Pilot Program

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Much has been written in recent months about the Department of Justice’s national Whistleblower Rewards Program, including a recent article I co-authored with Mike Gill entitled 7 Strategies to Comply with the DOJ’S New...more

Wiley Rein LLP

DOJ’s Corporate Whistleblower Pilot Program Hits the Ground Running: Is Your Compliance Program Ready?

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The U.S Department of Justice’s (DOJ or Department) Corporate Whistleblower Awards Pilot Program (Pilot Program) has hit the ground running, reportedly triggering more than 100 reports since it went live on August 1, 2024....more

Troutman Pepper

DOJ Updates Guidance on Corporate Compliance Programs With Focus on AI

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On September 23, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced that the U.S. Department of Justice (DOJ) updated its guidance on the Evaluation of Corporate Compliance Programs (ECCP). The DOJ’s...more

Bradley Arant Boult Cummings LLP

Whistleblower Language in Separation Agreements Results in Large Settlements with SEC

On September 9, 2024, the Securities and Exchange Commission (SEC) announced settlements with seven public companies relating to their use of separation agreements that the SEC says violate whistleblower protection rules by...more

Mintz

DOJ Reinforces Emphasis on Voluntary Self-Disclosure With Latest Updates to the Evaluation of Corporate Compliance Programs...

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On September 23, 2024, the Criminal Division of the United States Department of Justice (“DOJ” or the “Department”) revised its Evaluation of Corporate Compliance Programs guidance (the “ECCP”)....more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Eversheds Sutherland (US) LLP

DOJ emphasizes importance of AI risk mitigation, whistleblower protections, and clawback compensation policies

Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP). These updates discuss, for the first time,...more

Thomas Fox - Compliance Evangelist

Argentieri on the DOJ’s Corporate Whistleblower Awards Pilot Program

The Department of Justice (DOJ) recently unveiled the Corporate Whistleblower Awards Pilot Program (CWA) to bolster corporate enforcement efforts. Although the program has only been operational for a few weeks, it has already...more

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