منشور Gina Castellano

Check out Alexandra Douglas's latest whistleblowing post, this time on the new SDNY whistleblower program

Please take a few minutes to read this article about the Virginia law to strengthen reporting of elder financial abuse!

Client Alert! Recently, the Department of Justice Criminal Division announced its Whistleblower Pilot Program. This program indicates a crucial shift in the landscape of corporate enforcement and accountability. Here are 5 key points you need to know. Read here: https://lnkd.in/edNcay5c  #GentryLockeClientAlert #DOJ #Whistleblower

Earlier this week the Department of Justice’s (DOJ) Criminal Division announced that it was implementing a Pilot Program on Voluntary Self-Disclosures for Individuals. The program is “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations” by offering non-prosecution agreements (NPAs) to individuals who provide “original and actionable” information to the Criminal Division.   Our New York partner Josh Naftalis explores what this means for individuals looking to voluntarily self-disclose and why the new program is notable.   Read the full article here: https://lnkd.in/epyt-4Fj   #WhiteCollarCrime #CorporateCrime #Whistleblowing

In this client alert, we break down the essentials of the Southern District of New York’s pilot whistleblower program. Launched this month, the program encourages individuals to self-disclose criminal conduct with the goal of avoiding prosecution. We outline the program’s incentives, eligibility, and the covered misconduct. And we suggest that, for corporations, this new reporting avenue “is another reminder of the importance of both a robust compliance program and an effective internal reporting mechanism.” Read more: https://lnkd.in/ghwzRprJ #SDNY #Whistleblower #FinCEN #NPA   Authors: Anne Cortina Perry, Laurel Loomis Rimon, Anthony Barkow, and Ashlee Carrasco

In the news- DOJ's new corporate crime database is up, and beginning to add useful information. https://lnkd.in/e77vrt-S

Somehow, li'l ol' me scored an invitation to Nick Ephgrave’s inaugural speech as director of the Serious Fraud Office at RUSI last night. (Clearly being part of the Fraud Advisory Panel allows me to punch above my professional weight, which is inverse to my actual weight.)   Here are my highlights:   “SFO will play a greater role in the national effort to tackle fraud” … “looking at ways in which the SFO can support the Government’s Fraud Strategy.”   “SFO cases will be faster” with an “introduction of a rigorous and intrusive review process on our active cases, to make sure that we are continually focusing in on the core issues of our cases and not allowing ourselves to wander off” and piloting “technology assisted review”.   “SFO will be bolder, more pragmatic, more proactive.” “SFO will become the collaborator of choice for other agencies.” “I want to be the first to prosecute someone under the new provisions of the Economic Crime and Corporate Transparency Act” There was clearly a lot of ambition, and intent. Hopefully it will come to fruition. The full speech, minus the Q&A is here: https://lnkd.in/eMDKmf6u

I should probably be upset when someone says my career makes no impact, but I can't completely disagree with this FTAdviser opinion piece by Richard D Cannon, CISM. The really juicy stuff is on page two, where Cannon gets into: ⏳ Prosecuting fraud is time-consuming 🚽 Trials are massively backlogged 🌮 Fraud sentences are milder than the yellow Taco Bell hot sauce packets 👐 Spicier sentences don't really matter because we're collectively identifying and convicting such a small percentage of fraudulent activity Yep, yep, yep, yep. I agree with all these points, and mostly with the overall headline. But... I think there's a big difference between being impotent and not going into the bedroom at all. Reeling back from the creepiness of that last sentence, I mean that even ineffective measures still have some deterrent effect. Substantial? No way. Everyone leaves unsatisfied. But still, the fact that any action at all is being taken does deter the more casual or entry-level criminals. A good example of this is first-party misuse ("friendly fraud"). First-party misuse exists because it's not a criminal act and there are no legal or private penalties for committing it. Some reports estimate that 80% of chargebacks are first-party misuse and more than 50% of the population have committed the act. Other fraud rates are nowhere near that high. Doing something, 𝑎𝑛𝑦𝑡ℎ𝑖𝑛𝑔 𝑎𝑡 𝑎𝑙𝑙, makes a difference. So yes, I'm pretty impotent right now. I'm secure enough to say that. But I'm committed to the relationship and hope that we can walk a therapy journey together in the hopes of eventually being more...potent. Fraud deterrence is impotent when conviction rates are so low (https://lnkd.in/gSPvSEi7) #fraud #fraudmanagement #fraudprevention #fraudstrategy #payments #paymentfraud #identity #identityfraud #opinion #therapy #couplescounseling

As we gear up for the holiday season, safeguarding your finances is more crucial than ever. Financial Crimes Investigator Steve Geckle shares a few tips for avoiding fraud this upcoming holiday season. #FraudAwarenessWeek Learn more about protecting yourself against fraud: https://lnkd.in/eZ2dWbDP