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Image: The recent appellate court ruling to expand Dodd-Frank whistleblower protections again, even to those who don’t report misconduct to the SEC, does no favors for companies trying to find the right policies for anti-retaliation. Ken Gage, head of the whistleblower defense practice at law firm Paul Hastings, says the ...
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As companies strive to keep investigations internal, rather than risk high-profile regulatory intervention, improving the hotlines they use to solicit employee tips and concerns is crucial. Using metrics and industry benchmarks can help, but measuring the effectiveness of internal whistleblower efforts may be the hardest part. Some tips and trends ...
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PremiumAssessing the impact of the DOJ’s monitorship policy six months in
It has been nearly six months now since the Department of Justice’s (DOJ) Criminal Division released its memorandum on the selection of compliance monitors. This article provides a critical analysis of the monitorships that received early terminations, those that remain in place, and the broader compliance lessons they impart.