FCPAméricas Blog
Archive for Whistleblowers category:
Best Practices for Setting Up a Hotline
4.15.2015
A hotline is an important element of a compliance program. The Resource Guide to the FCPA mentions that “an effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation”. Similarly, the […]
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Whistleblowers: 2014 Year In Review
12.04.2014
The SEC 2014 Annual Report to Congress on the Dodd-Frank Whistleblower Program was published on November 17, 2014. This post highlights five relevant developments this year related to SEC whistleblowers. Increase in number of tips received by the SEC. The number of whistleblower tips the Commission receives annually continues to increase: 3,001 tips in the […]
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Whistleblowers: 2013 Year In Review
1.23.2014
Much has been written about FCPA enforcement trends in 2013. This post highlights five relevant developments of the last year related to SEC whistleblowers. Increase in the number of tips received by the SEC. The SEC 2013 Annual Report to Congress on the Dodd-Frank Whistleblower Program reports that “the number of whistleblower tips and complaints […]
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What FCPA Enforcement is Thinking in 2013
12.06.2013
What is the current thinking of FCPA enforcement officials at the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC)? At ACI’s 30th International Conference on the FCPA this year, two top officials provided insights (they clarified that their statements reflected their own views and not the views of their respective agencies). […]
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FCPA Compliance Lessons from “The Informant” (Part 2: Insights from a whistleblower)
8.23.2013
This is Part 2 of an interview with Mark Whitacre, the whistleblower who exposed ADM’s multi-billion dollar price fixing scheme and went to prison himself for defrauding the company too. You can read Part 1 here. For three years Mr. Whitacre wore a wire for the FBI. The movie “The Informant” was based on his […]