Apr. 23, 2025

U.K. Launches U.S.-Style Whistleblower Reward Program to Combat Tax Fraud – SFO May Be Next

Representing whistleblowers does not garner the same respect in London as it does in the United States, but these attitudes are starting to change. In a guest article, Mary Inman, a founding partner of Whistleblowers Partners LLP, discusses the expansion of a whistleblower incentives program to identify tax fraud in the United Kingdom and movement toward a similar program at the SFO. See this two-part series on the DOJ’s Corporate Whistleblower Awards Pilot Program: “A Look at Forfeiture and Culpability” (Aug. 14, 2024), and “Exclusions, NDAs and Goals” (Sep. 11, 2024).

Regional Risk Spotlight: Nigeria Poses Written and Unwritten Corruption Risks

Nigeria has some of the largest petroleum reserves in the world, making its extractive sector highly attractive to foreign investors. However, local laws in Nigeria require any company seeking to invest in that resource to partner with the government-owned Nigerian National Petroleum Company. And this is not the only local law foreign investors and companies seeking to do business in Nigeria must be aware of. The Anti-Corruption Report spoke with Ikemesit Effiong, a partner at risk and geopolitics research firm SBM Intelligence and chair of the technology committee at the Nigerian Bar Association’s Section on Business Law, to discuss the current state of bribery and corruption enforcement in Nigeria and what companies seeking to do business there need to know. See “How Energy Companies Can Manage Heightened Anti-Corruption Risk” (Oct. 23, 2024).

When and How to Audit Foreign Third Parties

Business relationships are governed by contracts that lay out rights and responsibilities for all parties. Auditing, at its most basic level, is just checking to make sure that a company’s business partners are behaving in alignment with those contractual obligations. Auditing third parties ensures that representations and warranties have been met, goods and services are delivered on time and in the proper manner, and funds are being used appropriately. However, third parties are often reluctant to open their books or their doors to outsiders, making this a challenging task. In a recent Strafford webinar, John Davis, a member at Miller & Chevalier, and Chris Miller, lead counsel for compliance and regional compliance officer for North America at General Motors shared how companies can take a risk-based approach to auditing their foreign third parties. See “Auditing Third Parties: A Ten-Step Checklist” (Nov. 29, 2017).

Novartis Appoints New Chief Legal and Compliance Officer

Novartis has announced that chief ethics and compliance officer Klaus Moosmayer is stepping down. In his place, Karen Hale, who is currently chief legal officer, has been appointed to the expanded role of chief legal and compliance officer. Hale, based in Basel, Switzerland, will lead the firm’s ethics risk and compliance function and will remain on the executive committee of Novartis. Moosmayer has been nominated to the advisory board of Deutsche Bank. See “Klaus Moosmayer of Novartis Explains Why Holistic Risk Assurance Is the Future of Compliance” (Jun. 23, 2021).

Five Steps for Effective Board Oversight on Cybersecurity Breach Response

New cybersecurity regulations, along with an uptick in post-breach regulatory enforcement actions and civil litigation, continue to push corporate boards toward more active oversight of their organizations’ cybersecurity risks and programs. This increasing pressure leaves some boards questioning how and to what extent they should be involved in responding to significant cybersecurity incidents. In this guest article, Alston & Bird partners Kim Peretti and Cara Peterman, and senior associate Lance Taubin, address the evolving regulatory and litigation landscape impacting the board’s cyber-risk governance and the role of boards in overseeing breach response and related disclosures. They also offer five steps for effective board oversight of cybersecurity incident response. See “Navigating SEC Cybersecurity Enforcement in a Post-SolarWinds World” (Jan. 3, 2024).