Month: April 2024
The Prisoner’s Dilemma Comes for Corporate Crime
As part of its continued effort to incentivize the voluntary self-disclosure of corporate crime, the Criminal Division of the Department of Justice (DOJ) announced a pilot program in mid-April 2024 that will offer non-prosecution agreements (NPAs) to individuals who voluntarily self-disclose information about certain corporate crimes. This program, along with […]
Fatal Flaws in SEC’s Amended Complaint Against SolarWinds
In March 2024, a coalition of more than 50 cybersecurity leaders and organizations called for dismissal of an amended complaint by the Securities and Exchange Commission (SEC) against SolarWinds and its chief information security officer (CISO), Tim Brown. Amici from the business community and the software industry, as well as […]
Addressing Workplace Complaints: A Critical Step in Light of Whistleblower Incentives
Prosecutors and regulators have recently offered significant financial rewards to whistleblowers to come forward in an effort to spur corporate enforcement. But whistleblowers aren’t made overnight – many times they are persuaded to act by the perception that management is ignoring their complaints. In light of increased efforts by prosecutors […]