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DOJ Criminal Division Announces Launch of FCPA Enforcement Pilot Program Apr 18, 2016

The Fraud Section of the U.S. Department of Justice (“DOJ”) Criminal Division announced on April 5, 2016 that it is launching a one-year Foreign Corrupt Practices Act (“FCPA”) enforcement pilot program (“Program”). This new initiative is designed to motivate companies to voluntarily self-disclose FCPA wrongdoing, fully cooperate with the Fraud…

CFTC Announces Largest Whistleblower Award To Date of More Than $10 Million Apr 12, 2016

A whistleblower who provided crucial original information that led to a successful U.S. Commodity Futures Trading Commission (“CFTC”) enforcement action received an award of more than $10 million on April 4, 2016, the largest award to date made by the CFTC's Whistleblower Program and the third award to a whistleblower…

New York Proposes AML Certification by Chief Compliance Officers Creating Potential Personal Criminal Liability Mar 28, 2016

The New York State Department of Financial Services (“NYSDFS”) has proposed a new rule in their anti-terrorism and anti-money laundering regulation that would subject chief compliance officers of New York financial firms to potential personal criminal liability. NYDFS over the last four years has conducted investigations into financial institution compliance…

Multi-State Cancer Care Provider Settles False Claims Act Allegations for $34.7 Million Mar 14, 2016

Cancer care provider, 21st Century Oncology Inc. and its wholly-owned subsidiary, South Florida Radiation Oncology LLC (“21st Century”), have reached a $34.7 million settlement with the U.S. Government regarding allegations that they performed and billed for procedures that were not medically necessary.  21st Century is the nation’s largest physician led…

Two Former Rabobank Traders Convicted and Sentenced to Prison in U.S. Over Libor Rigging Mar 14, 2016

Two former traders at Rabobank Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A., a Netherlands based bank (“Rabobank”), were sentenced to prison on March 10, 2016 by U.S. District Judge Jed S. Rakoff of the Southern District of New York, for the manipulation of the London Interbank Offered Rates (“LIBOR”) for the U.S. Dollar…

IRS Pays Whistleblowers $103 Million in FY2015: Whistleblower Retaliation Protection May Become Law in 2016 Feb 22, 2016

The IRS released its 2015 annual report for its Whistleblower Program on February 10, 2016 which disclosed that in 2015, 99 awards were made to whistleblowers totaling $103,486,677. This amount almost doubles the $52 million in awards made to whistleblowers in 2014. The annual report data indicates that this huge…

Dutch Company to Pay $795 Million to Resolve FCPA Bribery Probe in Uzbekistan Feb 19, 2016

Telecommunications giant, Amsterdam-based VimpelCom Limited and its wholly owned Uzbek subsidiary, Unitel LLC, agreed on Thursday, February 18, 2016, to pay $795 million in criminal fines, disgorgement and pre-judgment interest to U.S and Dutch enforcement agencies, including the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) for…

SEC Awards Company Outsider Whistleblower More Than $700,000 Jan 15, 2016

The Securities and Exchange Commission (“SEC”) awarded a company outsider more than $700,000 for providing information in a detailed analysis that led to a successful SEC enforcement action. The SEC did not identify the whistleblower or the company that is subject to the enforcement action due to confidentiality protections afforded…

No DoD Contracts for Companies that Restrict Employee Whistleblowers From Reporting Fraud, Waste or Abuse Dec 1, 2015

On October 29, 2015, the Department of Defense (“DoD”) renewed the Defense Federal Acquisition Regulation Supplement (“DFARS”) class deviation or policy implemented in February 2015 which prohibits the DoD from contracting with firms that require their employees or subcontractors to sign or abide by internal confidentiality agreements that would restrict…

Internal Whistleblowers Protected by Dodd-Frank Says Second Circuit Sep 11, 2015

On Thursday, September 10, 2015, a divided Second Circuit reversed and remanded a lower court’s dismissal of a whistleblower retaliation case by a former employee. The Court found that the sections of the Dodd-Frank Act that govern when a whistleblower has to report to the Securities and Exchange Commission (“SEC”)…