silver whistle on green background

Retaliation? Tell It to the SEC

Posted by - April 3, 2018
Implications for Compliance Program from the Digital Realty Ruling The Supreme Court ruled recently on the Digital Realty v. Somers case, and the decision is significant from a compliance standpoint; potential informants are incentivized to report directly to the SEC rather than through internal channels. Peter Rasmussen of Bloomberg Law…
lips partially sewn shut

The Power of Whistleblowers in the Modern Age

Posted by - March 23, 2018
Lessons Learned from the Trenches The #MeToo and #TimesUpNow social media campaigns sparked a movement to expose intimidating behavior and sexual assault in the workplace. Because of the resulting paradigm shift, harassed employees are empowered to speak up about wrongdoings. Corporate investigators Amy Conway-Hatcher and Bridget Moore discuss the need…
folder of fraud investigations

7 Tips to Evaluate In-House Investigations

Posted by - February 21, 2018
How Effective and Efficient is Your Process? In-house investigation teams are expected to be agile to be able to help organizations in addressing cases that come from whistleblowing channels and sustaining the ethical standards of the organization. By supporting your investigation teams with measures to assess effectiveness and efficiency you…
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Good News for Whistleblowers

Posted by - October 10, 2017
SEC Issues Statement on Cybersecurity High-profile data breaches seem to come fast and frequently these days. Last month, the Securities and Exchange Commission revealed it was the target of a cyberattack through which the criminals gained access to nonpublic information. With the announcement, the SEC declared its renewed focus on…
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5 Strategies to Infuse Compliance Companywide

Posted by - August 11, 2017
How the CEO Can Support Compliance Many executives view compliance as a “check the box” proposition. In this column, LeClairRyan attorneys Brian Lansing and Patrick Hurd argue that a focus on compliance should permeate the entire organization, in much the same way that Amazon obsesses about customer service. It all…
wells fargo building

Fallout Continues for Wells Fargo

Posted by - August 9, 2017
Evidence of Widespread Consumer Finance Violations Mounts On July 21, 2017, OSHA determined that Wells Fargo had unlawfully retaliated against a former branch manager who reported her colleagues for fraudulently opening customer accounts. The announcement marks the most recent in a series of negative repercussions following the bombshell CFPB announcement in September 2016…
placard reading Jeff Sessions on desk with American flags

AG Sessions Vows to Continue Enforcement of FCPA

Posted by - July 20, 2017
Penalties for Noncompliance Remain Severe Attorney General Jeff Sessions has identified enforcing the Foreign Corrupt Practices Act as a high priority for the Trump administration in its ongoing efforts to combat corporate misconduct.  News of this, along with other statements by officials within the Department of Justice, came as a…
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Africa: Fighting Corruption on Its Own Turf

Posted by - June 21, 2017
Bolstering Anti-Corruption Efforts in Africa While there have been enforcement actions against large multinational companies who have paid bribes while doing business in Africa, enforcement seems to be from foreign governments against these companies. There have been few cases where the host country prosecuted multinationals for paying bribes, given they…
canvas bag full of money

Don’t Mess with the SEC Whistleblower Program, Part 2

Posted by - April 11, 2017
We’re all in agreement that culpable whistleblowers should not be eligible for financial awards. But Dan Hurson argues that legislation already in place has guards against the potential of awarding guilty parties. And the vast majority of whistleblowers have kept their hands clean anyhow. The inclusion of a “co-conspirator” disqualifier…
man cutting $50 bill

Don’t Mess with the SEC Whistleblower Program, Part 1

Posted by - April 10, 2017
One of the more hotly contested issues with Dodd-Frank was that the Act would encourage misconduct – that the promise of ample compensation for whistleblowers would in fact incentivize individuals to direct or participate in criminal behavior, then reward those culpable for the wrongdoing. But the authorities have made clear…
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Strengthening Protections for Federal Government Whistleblowers

Posted by - April 10, 2017
While many expect the new administration and Congress to chip away at employee protections, several initiatives in Congress and the executive branch suggest a trend in the opposite direction for federal employees. Two Acts currently pending in Congress are designed to fill gaps in protection for federal employees and prevent…
man in suit holding red whistle

Whistleblowing: More Than Just Bounty Hunting?

Posted by - March 24, 2017
Australia’s stance on financial remuneration for whistleblowers could be changing. The nation recently launched a Parliamentary inquiry into the appropriate legal framework for whistleblowers. Currently Australia offers no financial compensation for whistleblowers; supporters feel a “bounty” system is inappropriate, but it could be a profitable business.