Cochise settles a circuit split and effectively lengthens the potential period of a company’s vulnerability to qui tam suits over alleged False Claims Act violations.
The risk of fraud is a serious concern for all types of enterprises, but fraud can be particularly damaging to a nonprofit organization, for which a damaged reputation can have devastating consequences.
I am constantly reminding boards and Chief Executive’s or CEO’s of the strategic importance of ethics and values and that they should not be underestimated.￼
DOJ Evaluation of Corporate Compliance Programs
Tipsters have grown frustrated with the length of time it has taken the the SEC (“Commission”) to determine whether a tip warrants a reward.