Archives: Compliance Tip

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Effective Compliance Programs Require a Commitment from the Top

Written by Jessica L. Sussman, Joseph C. Toris and Summer Law Clerk Bridget Jeong We follow the leader wherever we go, and that applies to compliance, as well. While federal and state laws require organizations to adopt compliance programs, a low level of commitment to these compliance efforts from the highest levels of management can … Continue Reading

Record High Awards and Supreme Court Decision Further Incent Potential Whistleblowers to Report Conduct to the SEC

On March 19, 2018, the Securities and Exchange Commission (“SEC”) announced its highest ever Dodd-Frank Act (“DFA”) bounty awards to three whistleblowers. These SEC awards represent a new milestone in the SEC’s ongoing efforts to incentivize would-be whistleblowers to report unlawful conduct directly to the Commission. Two whistleblowers will divide a nearly $50 million award … Continue Reading

SEC Announces Third-Highest Award Ever to Whistleblower

Written by Richard C. Paul On May 17, 2016, the Securities and Exchange Commission (SEC) announced that it would award between $5 million and $6 million, the third-highest award ever, to a whistleblower who provided information detailing securities violations committed by the whistleblower’s former employer. Under the so-called “bounty” provision of the Dodd-Frank Act, the … Continue Reading

Greater Emphasis On Corporate Compliance Programs

Early in 2015, the FBI launched a new program aimed at routing out foreign bribery in which it established three dedicated international corruption squads, based in New York City, Los Angeles, and Washington, D.C. The FBI reported that members of these three squads—agents, analysts, and other professional staff—have a great deal of experience investigating white-collar … Continue Reading

Best Practices When a Current Employee Complains

It is vital that all employers investigate internal complaints that may be covered under a variety of laws, including EEO laws (for example, Title VII, ADA, ADEA, and state EEO laws), whistleblower laws such as, Sarbanes-Oxley, Dodd Frank (and state whistleblower laws), OSHA, the False Claims Act, and the NLRA. Additionally, employers conduct investigations in … Continue Reading
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