Tag Archives: Joshua A. Naftalis

Paying Criminal Whistleblowers: DOJ Announces A Program to Pay For Tips, and the SFO Is Considering Doing So Too

by Joshua A. Naftalis, Matt Getz, and Tracey Dovaston

From left to right: Joshua A. Naftalis, Matt Getz, and Tracey Dovaston. (Photos courtesy of Pallas Partners LLP).

In the past two weeks, the U.S. Department of Justice (DOJ) and the U.K. Serious Fraud Office (SFO) each made announcements about paying financial bounties to whistleblowers.  On March 7, 2024, U.S. Deputy Attorney General Lisa Monaco announced a new DOJ whistleblower program that will compensate individual whistleblowers for reporting corporate or financial misconduct previously unknown to DOJ.  This announcement followed a February 13, 2024 speech by SFO Director Nick Ephgrave, who said that he supported the idea of paying whistleblowers.    

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U.S. White-Collar and Regulatory Enforcement: Some Thoughts for 2024

by Joshua A. Naftalis and Melissa Kelley

Photos of authors

Left to right: Joshua A. Naftalis and Melissa Kelley (Photos courtesy of Pallas Partners LLP)

2023 was another busy year in the U.S. white-collar and regulatory enforcement areas.  As we begin 2024, a few of the Government’s recent enforcement policies and priorities should be kept front of mind: (1) the Department of Justice’s (DOJ) focus on corporate criminal enforcement; (2) DOJ’s related prioritization of sanctions evasion and anti-foreign bribery enforcement; (3) the U.S. Securities and Exchange Commission’s (SEC) and the Commodity Futures Trading Commission’s (CFTC) diverging policies on “no-admit/no-deny” settlements; and (4) the cryptoasset space.  

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SDNY Announces Whistleblower Pilot Program to Incentivize Self-Disclosure of Financial Fraud and Public Corruption

by Joshua A. Naftalis, Anastasia Cembrovska, Brianna Hills Simopoulos, and Jingxi Zhai

Photos of the authors

Joshua A. Naftalis, Anastasia Cembrovska, Brianna Hills Simopoulos, and Jingxi Zhai (photos courtesy of Pallas Partners LLP)

The U.S. Attorney’s Office for the Southern District of New York (“SDNY”) has rolled out a first-of-its-kind whistleblower program that offers individuals who self-report financial fraud or public corruption a path to a non-prosecution agreement.  U.S. Attorney Damian Williams unveiled the pilot program on January 10, 2024, which provides specific guidance for when the SDNY will enter into a non-prosecution agreement in exchange for an individual’s “early and voluntary self-disclosure of criminal conduct.” 

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