We know that a co-worker has taken sensitive information. Do we report this or not? Most people might want to report it but either don’t know who to speak with or have a hard time identifying whether or not this is truly something that needs to be reported.
Management that turns deaf ears when subordinates report false billing or illegal marketing in dealing with federal or state governments can unleash a torrent of financial and reputational harm on the company. Indeed, that scenario is just the sort of situation that can turn into a full-blown, multi-million-dollar whistleblower settlement brought by a company insider under qui tam provisions of federal and state False Claims Acts.
The Importance of Compliance Audits in Today’s Intensive Enforcement Environment and Whistleblower Culture
Ben Tyman of Mintz Levin explains why periodically conducting independent, confidential compliance audits is the best way to assess these compliance risks as well as to test the efficacy of your internal compliance program in doing what, at its core, it is supposed to do.
This article by Michael Littenberg of Schulte Roth & Zabel highlights five compliance items — some of which are still at the far end of the horizon — that all public companies should have on their short list.
According to Joe Palazzolo’s recent post in Corruption Currents, “a person familiar with the matter” said the SEC “has been receiving at least one tip a day about potential foreign bribery violations” pursuant to Dodd-Frank’s new whistleblower provisions.
In one way, shape or form, whistleblowing is the theme of this week’s Friday Roundup.
The FCPA bar is an active group of writers. And quick. This post includes a sampling of other views on the whistleblower provisions of the Dodd-Frank financial reform bill signed by President Obama last week.
Sections 922-924 of the Dodd-Frank financial reform bill have the potential to impact FCPA enforcement because it creates new whistleblower provisions applicable to all securities laws violations and the FCPA is part of the Securities and Exchange Act of 1934.
Authors from Miller & Chevalier discuss the implications of Senator Chris Dodd’s recent proposal that establishes a new program to reward whistleblowers who assist the SEC in an investigation of securities violations such as violations of the FCPA.