Tagged: whistleblowers

Episode 75 — 2018 False Claims Act Review

The Justice Department reported its 2018 fraud statistics showing $2.8 billion in recoveries under the False Claims Act.  While this number is staggering, fiscal year 2018 recoveries were down from than $500 million from fiscal year 2017.  Nonetheless, companies in the healthcare, defense and financial industries continue to face significant False Claims Act risks. In this episode, Michael Volkov interviews Jessica Sanderson, Of Counsel, at...

Episode 61 — How to Implement and Promote a Speak Up Culture

Companies face a myriad of risks that can cause significant legal and reputational risks.  A company’s employees are critical sources of concerns to prevent and detect problems.  Employees have to be encouraged to raise concerns to help the company address these problems proactively.  As a result, it is critical for companies to invest and promote its speak up culture to maximize employee communication and prevent...

Corporate Attitudes: When Speak Up Means Keep Quiet

As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives.  So, our kids start to speak up and we listen, patiently, but at some point, our patience wears thin, and we are not as interested or willing to listen.  Our children begin to question our...

Yates, Whistleblowers and FCPA Pilot Project: Re-Examining Your Internal investigation Protocols

Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies have to “reinvent” compliance programs to incorporate new priorities and demands. Many companies have established complaint systems and internal investigation programs to conduct routine and serious investigation. In most cases, these systems do not adequately address whistleblower...