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Regulation Securities Litigation White Collar Crime

Disclosure of Investigations: Whether and When for Public Companies

You should be thinking about disclosure long before you even hear from a whistleblower, specifically, in terms of setting up policies and procedures governing how to handle the information flow from the investigative side of the house to the disclosure side.

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You are the general counsel of a mid-cap company trading on the New York Stock Exchange. Because of your firm’s international work, you have instituted a global anti-corruption compliance program, complete with a whistleblower hotline. Sunday night, an anonymous call comes in on the hotline. The manager of your Nigerian subsidiary has been inviting the tax minister on weekly yacht cruises in exchange for better tax treatment. Being the good corporate citizen you are, you quickly commence an internal investigation. On Monday afternoon, the Securities and Exchange Commission sends a document request and tells you it has opened an informal investigation.

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