News & Analysis as of

White Collar Crimes Internal Reporting

Lathrop GPM

[Webinar] New DOJ Corporate Whistleblower Program - September 10th, 12:00 pm - 12:50 pm CT

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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

Oberheiden P.C.

A Handbook for SEC Whistleblowers

Oberheiden P.C. on

The U.S. Securities and Exchange Commission’s (SEC) Whistleblower Program was created in Section 922 of the Dodd-Frank Act of 2010, which amended the Securities Exchange Act to include a whistleblower provision. It has since...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

Polsinelli on

On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Dentons

Ep. 2 - Why Anonymous Reporting is the Cornerstone of Your Compliance Program

Dentons on

When was the last time your organization received an anonymous compliance concern?  Has it been so long you can’t recall? Maybe you consider yourself lucky that the organization has never received a concern on your watch, or...more

Thomas Fox - Compliance Evangelist

How Triage and Investigations Can Drive a Culture of Speak Up

I recently concluded a podcast series with Case IQ. Over this series, I visited with Sharlyn Lauby, Jakub Ficner, Kenneth McCarthy, and Meric Bloch on the different facets of a great speak-up regime and how each of those...more

Thomas Fox - Compliance Evangelist

Speaking Up is Awesome

We are on a run of some great, informative and incredibly useful books by some super star compliance professionals. A couple of weeks ago Mary Shirley released Level Up. In her book, Mary shared forward-thinking hacks and...more

Fisher Phillips

Top 20 Questions to Ensure Your Compliance Program Helps You Minimize Corporate Criminal Risks

Fisher Phillips on

Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more

The Volkov Law Group

NAVEX Annual Hotline and Incident Report: A Mixed Bag of Reporting Trends

The Volkov Law Group on

NAVEX recently released its annual Hotline and Incident Management Report.  Given NAVEX’s strong position in the hotline service market, NAVEX has access to a large volume of reporting data.  As a result, its annual report is...more

Jones Day

SEC Awards $28 Million+ to Whistleblower for Tip Relating to 2018 FCPA Settlements

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On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more

The Volkov Law Group

NAVEX Global Incident Management Study Confirms Impact of COVID-19 on Employee Reporting

The Volkov Law Group on

NAVEX Global produces a number of important compliance program reports.  NAVEX Global always has played an important thought-leadership role in the ethics and compliance field....more

Skadden, Arps, Slate, Meagher & Flom LLP

Blowing the Whistle: Protections Under EU Law

On 23 October 2019, the European Parliament and the European Council adopted the Whistleblower Protection Directive (Directive) to set a minimum standard for the protections EU member states must provide to whistleblowers. ...more

The Volkov Law Group

The EU Speaking Up Regime – Plenty of Process and Protection but no Bounties

The Volkov Law Group on

In 2019 the EU introduced new rules to enable whistleblowers to report about EU law irregularities (https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32019L1937), which EU countries must implement into their...more

Jones Day

Japan Legal Update - Volume 52

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Investigations & White Collar Defense - Amendment to Whistleblower Protection Act - On June 8, 2020, the Japanese Diet passed a bill to amend the Whistleblower Protection Act ("Act"). The bill was introduced amid a...more

Thomas Fox - Compliance Evangelist

Answering DOJ Questions on Confidential Reporting

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more

Thomas Fox - Compliance Evangelist

Introduction to Internal Reporting and Investigations on 31 Days to a More Effective Compliance Program

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more

The Volkov Law Group

Incident Data and Intra-Company Cooperation

The Volkov Law Group on

The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

The Volkov Law Group

A Speak Up Culture Depends on Follow Through and Accountability

The Volkov Law Group on

Corporate leaders often talk to the talk when it comes to a Speak Up culture.  In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more

Kramer Levin Naftalis & Frankel LLP

A Comprehensive Whistleblower Protection for the EU

On April 23, Kramer Levin reported on the European Parliament’s approved proposal for the adoption of a whistleblower protection directive. On Oct. 7, the Directive on protection of persons reporting breaches of Union law...more

The Volkov Law Group

The Importance of Whistleblowers to a Speak Up Culture

The Volkov Law Group on

The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused  attention on an important issue – encouraging whistleblowers as part of a speak up culture and...more

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 5 – Reporting and Investigations

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more

The Volkov Law Group

Assessing Your Hotline System

The Volkov Law Group on

Employee hotlines are – sorry about this – a “hot” topic these days in compliance. NAVEX Global’s recent study confirmed the importance of an effective hotline system. Companies that implement robust and widely-used...more

Thomas Fox - Compliance Evangelist

What is Innovation in Compliance and Why is it so Hard? Part III

Over the past few blog posts, I have been exploring a recent article in Harvard Business Review by Gary P. Pisano, entitled “The Hard Truth About Innovative Cultures”. Pisano says the conventional wisdom is innovative...more

Thomas Fox - Compliance Evangelist

How Compliance Adds to the Bottom Line

I have long articulated that companies that have robust compliance programs are more efficient, better run and more profitable organizations. ...more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part III

One of the key lessons I learned in doing the research for The Complete Compliance Handbook is how compliance programs best practices have evolved beyond the basic requirements laid out in the 2012 FCPA Guidance’s Ten...more

The Volkov Law Group

Time for Companies to Establish an Independent Corporate Ombudsman

The Volkov Law Group on

Corporate commitment to speak up cultures is suffering. The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey contained a critical finding – corporate instances of retaliation against employee...more

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