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    Apr. 23, 2025

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

Representing whistleblowers does not garner the same respect in London as it does in the United States, but the tide is turning, according to Mary Inman, a founding partner of Whistleblowers Partners LLP. In this guest article, Inman discusses the expansion of a whistleblower incentives program to identify tax fraud in the U.K. and movement toward a similar program at the SFO. See our 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).

What Does the FCPA EO Mean for European Enforcement?

There is no doubt that the FCPA has been the most impactful piece of global legislation in the fight against corruption, and its enforcement by the DOJ has been the “gold standard” for decades. So, on the face of it, the recent U.S. executive order pausing FCPA enforcement (FCPA EO) issued by President Donald Trump on February 10, 2025, has the feel of an existential change when it comes to the crackdown on international corruption. However, recent global trends – across Europe in particular – point to a shift in the balance. In this guest article, Laim Naidoo, a partner at Hogan Lovells looks at how developments in the U.S. could impact anti-corruption efforts in the U.K., France, Switzerland, Germany, Italy, Spain and beyond. For more on the FCPA EO, see our two-part series: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

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, but local laws in Nigeria require any company seeking to invest to partner with the government-owned Nigerian National Petroleum Company. This is just one example of the local laws foreign investors and companies must be aware of when seeking to do business in Nigeria. 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 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).

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).

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).

International Trade and Anti-Corruption Lawyer Joins Honigman in D.C.

Honigman has welcomed Daniel Wendt as a partner in its government relations and regulatory practice group and regulatory department in Washington, D.C. Wendt joins from Miller & Chevalier. For commentary from Wendt, see our three-part series on the DOJ’s 2024 edits to the ECCP: “Some History and AI Expectations” (Nov. 6, 2024), “Data Analytics to Find Risks and Measure Effectiveness” (Nov. 20, 2024), and “Speaking Up, Compliance Resources and Lessons Learned” (Dec. 4, 2024).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.