The SEC 2016 Annual Report to Congress on the Dodd-Frank Whistleblower Program was published on November 15, 2016. This post highlights seven relevant aspects of the report.
Continuous 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 2012 fiscal year, 3,238 tips in the 2013 fiscal year, 3,620 tips in the 2014 fiscal year, 3,923 tips in the 2015 fiscal year and 4,218 tips in fiscal year 2016. From fiscal year 2012, the first year for which we have full-year data, to fiscal year 2016, the number of whistleblower tips has grown more than 40 percent. Since August 2011, when the SEC’s O... Read more
A new book published recently in the United States is an excellent tool for FCPA compliance practitioners doing work in Latin America. The book, entitled The FCPA in Latin America: Common Corruption Risks and Effective Compliance Strategies for the Region, was written by Matt Ellis, who has extensive experience in international anti-corruption compliance and enforcement, with particular focus on Latin America (his full CV is available here), where he lived and worked.
With 214 pages divided into 8 chapters, the book covers numerous areas of FCPA compliance in Latin America and is must-read for anyone ha... Read more
Brazil’s “10 Measures Against Corruption”: Chamber of Deputies Approves Changes to Lava Jato Task Force Proposal
On March 20, 2015, members of the Brazilian Federal Prosecution Service (“MPF”) serving on the task force responsible for prosecuting the Operation Lava Jato (“the Task Force”), launched a campaign called “10 Measures Against Corruption.” Drawing on past experience with anti-corruption investigations, the Task Force developed a legislative proposal to encourage the prosecution of corruption cases and to diminish impunity. Past blo... Read more