DOJ’s New Whistleblower Reward Program Will Supercharge White Collar Enforcement
Zuckerman Law Blog
by Jason Zuckerman
2w ago
In a speech today at the ABA’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new pilot whistleblower reward program that will fill significant gaps in existing whistleblower reward programs by paying awards from the DOJ’s Assets Forfeiture Fund. The DOJ plans to announce the details of the program in approximately 90 days and launch it this year. Monaco stated that the program will “create new incentives for individuals to report misconduct.” Similar to the “original information” requirement that a whistleblower must meet to qualify for an SEC whistl ..read more
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Whistleblower Rewards for Sanctions Evasion Whistleblowing: How to Detect Sanctions Evasion in the Maritime and Transportation Industries
Zuckerman Law Blog
by Jason Zuckerman
3M ago
Financial Incentives for Disclosing Sanctions Evasion Under the whistleblower provisions of the Anti-Money Laundering Act (AMLA), a whistleblower who voluntarily reports original information about U.S. sanctions evasion that leads to a  judicial or administrative action imposing penalties exceeding $1,000,000 can obtain an award of 10% to 30% of the collected monetary sanctions.  To qualify for a whistleblower award under the AMLA, a whistleblower must provide original information to their employer, the U.S. Department of Treasury (Treasury), or the U.S. Department of Justice (DOJ ..read more
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Financial Incentives for Sanctions Evasion Whistleblowers Supercharge Sanctions Enforcement and Strengthen National Security
Zuckerman Law Blog
by Jason Zuckerman
4M ago
DOJ’s Increased Focus on Intersection of Corporate Crime and National Security On November 28, 2023, Principal Associate Deputy Attorney General Marshall Miller delivered remarks at the New York City Bar Association’s International White Collar Crime Symposium, concerning the DOJ’s efforts to “address the rapidly increasing intersection between corporate crime and the risks that threaten both U.S. and global security.”  Those risks include: terrorist financing; sanctions evasion; export control circumvention; and cybercrime and crypto-enabled crime. A growing share of the DOJ’s corporat ..read more
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What is the Impact of a Whistleblower’s Job Duties on Whistleblower Reward Eligibility?
Zuckerman Law Blog
by Jason Zuckerman
4M ago
The position that a whistleblower holds when they report fraud or some other unlawful conduct can have a significant impact on their eligibility for a whistleblower reward.  It is critical to assess this issue early on because it can make the difference between qualifying for an award or being deemed ineligible for an award.  For example, a compliance officer who immediately reports a securities law violation to the Securities and Exchange Commission (SEC) may not qualify for an award, but if they report the violation internally and then wait 120 days to report it to the SEC, they co ..read more
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False Claims Act Retaliation Decision Calls into Question Heightened Notice Standard for Fraud Alert Employees
Zuckerman Law Blog
by Jason Zuckerman
5M ago
A recent decision denying summary judgment in a False Claim Act retaliation case signifies further erosion of the “distinct possibility” standard that governed FCA retaliation claims in several circuits prior to the adoption of the 2009 amendments to the FCA and calls into question why any court would continue to apply a heightened notice standard to fraud alert employees.  Judge Adelman’s construction of FCA protected conduct in Patzer v. Sikorsky Aircraft Corp. is consistent with the text and purpose of the FCA and recognizes that Congress intended to encourage whistleblowers to stop vi ..read more
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CFTC Whistleblower Program’s FY23 Report to Congress Reveals Continued Success of the Program in Protecting Markets and Customers
Zuckerman Law Blog
by Jason Zuckerman
5M ago
CFTC Whistleblower Office Receives the Highest Number of Whistleblower Tips and Award Applications Since the Inception of the Program Today the CFTC’s Whistleblower Program issued its annual report to Congress for FY23.  The report reveals that the program continues to be a key enforcement tool for the CFTC.  Since the inception of the program, the CFTC has awarded approximately $350 million to whistleblowers, and whistleblower disclosures have led to more than $3 billion in enforcement sanctions.  In a statement accompanying the report, Commissioner Christy Goldsmith Romero und ..read more
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SEC Charges Against SolarWinds Signal Resolute Cybersecurity Enforcement and May Spur Surge in Cybersecurity Whistleblowing to SEC
Zuckerman Law Blog
by Jason Zuckerman
5M ago
Today the SEC filed a complaint against SolarWinds Corporation and its CIO for fraud and internal control failures relating to allegedly known cybersecurity risks and vulnerabilities. According to the complaint, SolarWinds defrauded investors by overstating its cybersecurity practices and understating or failing to disclose known risks.  The SEC’s complaint signifies robust SEC enforcement of cybersecurity-related securities violations, including failure to disclose known material cybersecurity risks and failure to maintain adequate cybersecurity controls.  In a press release announc ..read more
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How to Report Swaps Manipulation or Swaps Reporting Violations and Qualify for a CFTC Whistleblower Award
Zuckerman Law Blog
by Jason Zuckerman
5M ago
How Whistleblower Disclosures of Swaps Manipulation or Swaps Reporting Violations Can Qualify for CFTC Whistleblower Awards Under the CFTC Whistleblower Program, whistleblowers are eligible for monetary awards when they voluntarily provide the CFTC with original information about violations of the Commodity Exchange Act (“CEA”) that lead to a successful enforcement action resulting in monetary sanctions exceeding $1,000,000. CFTC-regulated swaps, including Foreign Exchange (“FX”) Forwards and FX Swaps, pose significant systemic risks.  Indeed, “the continued pursuit of various opport ..read more
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Strengthened Enforcement of Sanctions Evasion Enhances Incentives for Sanctions Whistleblowers
Zuckerman Law Blog
by Jason Zuckerman
6M ago
Last year, Congress amended the whistleblower rewards provision of the Anti-Money Laundering Act (AMLA) to require the Treasury to pay an award to a whistleblower for a voluntary disclosure of original information about sanctions evasion that results in the collection of sanctions above $1 million.  In particular, the AMLA whistleblower reward law incentivizes whistleblowers to disclose violations of the International Emergency Economic Powers Act, sections 5 and 12 of the Trading With the Enemy Act, or the Foreign Narcotics Kingpin Designation Act. A whistleblower can report vi ..read more
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Thomson Reuters Practical Law Publishes Profile of Whistleblower Lawyer Jason Zuckerman
Zuckerman Law Blog
by Matthew Stock
7M ago
Checking in with Jason Zuckerman whistleblower lawyer ..read more
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