News & Analysis as of

Whistleblowers Compliance Enforcement Actions

Dorsey & Whitney LLP

DOJ on Campus: DOJ’s First Intervention in False Claims Act Case Alleging University Knowingly Failed to Meet Contractual...

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Cybersecurity requirements for federal contractors and grantees continue to proliferate—and those requirements do not just come with contractual risk. Increasingly, the United States government is leveraging enforcement...more

Holland & Knight LLP

DOJ Brings Suit Against University Under Its Civil Cyber-Fraud Initiative

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Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more

Benesch

White Collar Quarterly Report - August 2024

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In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...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

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

Robinson+Cole Data Privacy + Security Insider

Department of Justice Maintains Its False Claims Act Enforcement Focus on Government Contractor Cybersecurity

On June 17, the Department of Justice (DOJ) announced settlements of alleged False Claims Act (FCA) violations associated with cybersecurity requirements in contracts to provide a secure environment for online applications...more

Kohn, Kohn & Colapinto LLP

The Double-Edged Impact of AI Compliance Algorithms on Whistleblowing

As the implementation of Artificial Intelligence (AI) compliance and fraud detection algorithms within corporations and financial institutions continues to grow, it is crucial to consider how this technology has a twofold...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - June 6th, 8:00 am - 5:00 pm CT

How do enforcement priorities impact your compliance program? Supply chains, tech tools, consumer data, the use of sanctions, the list is long — there are a vast number of organizational processes and procedures under...more

Alston & Bird

DOJ Reports Record Number of New False Claims Act Matters, Recoveries for 2023

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Our False Claims Act (FCA) Team examines the Department of Justice’s increased focus on enforcement of the FCA, especially in health care matters. The DOJ initiated over 1,000 FCA matters in one year for the first time....more

Health Care Compliance Association (HCCA)

In Biggest Stark-Based FCA Settlement Ever, Indiana Hospital Pays $345M, Has Unusual CIA

Community Health Network (CHN) in Indiana has agreed to pay $345 million to settle false claims allegations that it paid over-the-top salaries to hundreds of physicians and rewarded them for their referrals in violation of...more

K&L Gates LLP

SEC Enforcement Targets Anti-Whistleblower Practices in Financial Firm's Release Agreements With Retail Clients

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As the year gets underway, the Securities and Exchange Commission (SEC or Commission) is continuing its ongoing enforcement efforts to target anti-whistleblower practices by pursuing a broader range of entities and...more

McDermott Will & Emery

[Webinar] 2024 Enforcement Outlook Series | Key Insights on Compliance and Enforcement Priorities for the Year Ahead - February...

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We’re looking forward to another year of our Enforcement Outlook webinar series, which we’ve designed to keep you up to date on the enforcement trends that might impact your organization’s compliance strategy....more

BakerHostetler

Employers Beware: Broad Confidentiality and Severance Clauses May Violate Whistleblower Protection Laws

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Employers should check their confidentiality and severance agreements for a common oversight that, for some, is becoming a costly error. Recent enforcement activity by the Securities and Exchange Commission (SEC) of Rule...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Attorney for SDNY Launches Whistleblower Program To Encourage Self-Disclosure by Individuals

On January 10, 2024, Damian Williams, U.S. Attorney for the Southern District of New York (SDNY), announced the creation of that office’s Whistleblower Pilot Program (Program). This initiative provides notice of the...more

A&O Shearman

White collar crime enforcement in Germany: trends and developments

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German authorities have intensified and accelerated their enforcement activities in 2023, following a slowdown of both investigations and court proceedings during the pandemic. This had led to a surge of dawn-raids in...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

NAVEX

Compliance Lessons from Recent SEC Whistleblower Protection Actions

NAVEX on

A trio of enforcement actions brought by the Securities and Exchange Commission in September sounds a warning bell for all companies to revisit their existing employee agreements, being particularly mindful of potential...more

Alston & Bird

SEC Enforcement Director Clarifies Compliance Violation and CCO Liability

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Our Investment Funds and White Collar Teams interpret how the Securities and Exchange Commission approaches its enforcement in three aspects: whistleblower restraints, self-reporting and cooperation, and compliance officer...more

Proskauer - The Capital Commitment

Words Matter: Three Key Steps to Mitigate SEC Enforcement Risks Relating to Whistleblower Carveout Language

Since 2015, the SEC has brought nearly two dozen enforcement actions for violations of the whistleblower protection rules under Rule 21F-17(a) against employers for actions taken to impede reporting to the SEC. The bulk of...more

Holland & Knight LLP

SEC Settlements Over Whistleblower Protections Pile Up

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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

Allen Matkins

Has The SEC Put The Proverbial Horse Before The Cart?

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In a recently settled administrative proceeding, the Securities and Exchange Commission took the position that an employer took action to impede potential whistleblowers when as a condition of receiving separation pay, the...more

Health Care Compliance Association (HCCA)

[Event] 2023 Healthcare Enforcement Compliance Conference - November 5th - 7th, Washington, DC

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us at HCCA’s Annual Healthcare Enforcement Compliance Conference to...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

Health Care Compliance Association (HCCA)

[Event] 2023 Board & Audit Committee Compliance Conference - October 23rd - 24th, Fort Lauderdale, FL

Discover today's best practices for your role in healthcare compliance oversight - The Office of Inspector General of Health and Human Services expects healthcare board members, board audit/compliance committee members,...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

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