Strategic considerations for organizations conducting internal investigations and contemplating self-disclosures amidst heightened whistleblower incentives

Partner Matthew Sullivan and senior associate Tina Milburn have authored an article for the New York Law Journal on how in-house counsel and compliance officers can navigate the challenges of conducting internal investigations and evaluating potential self-disclosures in light of new incentives for whistleblowers.

In recent years, the U.S. Department of Justice (DOJ) and other U.S. enforcement authorities have taken steps to further incentivize self-disclosure of potential wrongdoing by companies in exchange for declinations, non-prosecution agreements, or reduced financial penalties. Now, new whistleblower incentives underscore the importance of investing in corporate compliance programs that are fully equipped to prevent, detect, investigate, and remediate wrongdoing.

The full article can be found here.

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