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Articles

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Recent SEC Whistleblower Awards Highlight Importance of Internal Reporting

USA - June 11 2019 The SEC’s most recent whistleblower awards highlight the importance of internal reporting to a company’s compliance program and especially how a...

Jennifer Kies Mammen, Elaine Drodge Koch, Jennifer L. Berhorst.

Supreme Court Resolves False Claims Act Circuit Split - Ruling gives individual relators the benefit of the government knowledge limitations period

USA - May 17 2019 The False Claims Act (FCA) has two limitations periods: 1) within 6 years after the violation occurred, or 2) within “3 years after the date when...

Cliff Stricklin, Laura S. Perlov, Michael J. Hofmann.

SDNY Chief Judge Finds that Government Outsourced Investigation to Law Firm

USA - May 8 2019 After a five-year, multi-million dollar investigation by outside counsel, a large financial institution settled allegations of LIBOR manipulation on...

Austin V. Campriello, Cliff Stricklin.

DOJ New Guidance Document on Corporate Compliance Programs - Useful Compilation of Previous Policies

USA - May 2 2019 The U.S. Department of Justice (DOJ) recently issued a Guidance Document for its Evaluation of Corporate Compliance Programs. The Guidance Document...

DOJ Tweaks Corporate Enforcement Policy

USA - March 14 2019 When DOJ announced its FCPA Corporate Enforcement Policy in 2017 (later expanded to all corporate criminal defendants...

Jennifer Kies Mammen.