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BUSINESS CRIMES BULLETIN

October 2010

Deploying Countermeasures to the SEC’s Dodd-Frank Whistleblower Awards

By Toby J.F. Bishop and Mohammed Ahmed

Section 922 of Dodd-Frank created awards of 10%-30% of monetary sanctions for whistleblowers who report to the SEC original information leading to securities law enforcement actions that recover more than $1 million. Here are 10 actions organizations might take to help mitigate the increased regulatory risk this change may create.

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CYBERSECURITY LAW & STRATEGY

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British Billionaire's Suit Over Alleged Leak Offers First Test of Privacy Law

Gilbert Chagoury, a British billionaire and philanthropist was denied a visa last year to enter the United States because, according to the U.S. government, he was suspected of supporting terrorism. Chagoury denies the allegation, saying the U.S. Department of State relied on bad intelligence. And now he's suing federal agencies that he claims leaked information about him to a reporter. His suit is thought to be the first case brought under the Judicial Redress Act, which President Barack Obama signed in February.

THE CORPORATE COUNSELOR

The New FCPA Cooperation Plan

On April 5, 2016, the DOJ issued an Enforcement and Guidance Plan concerning the FCPA. While the new Plan could be interpreted as a novel departure from past precedent, careful analysis reveals that it does little to alter or clarify how the DOJ will review cases or reward companies for significant cooperation in addressing anti-corruption global issues.