Whistleblower Awards

law
$250 million
Amount awarded by the SEC to whistleblowers since the inception of the agency’s whistleblower program in 2011. Enforcement actions from whistleblower tips have resulted in more than $1 billion in financial remedies.
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FCPA violations

$820 million and rising
Walmart’s legal fees and other costs associated with DOJ and SEC investigations of alleged FCPA violations, including revamping its global compliance program. (2012 to date)
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FCPA Compliance: 5 Overlooked Issues

1. Single Compliance Program: A “one size fits all” compliance program does not often work. Must take into account risk/cultural aspects of every country and have a proportionate global program. Must be able to demonstrate compliance program works effectively and has been tested: Prevent-Detect-Respond. Materiality does not matter, issue is whether your internal control system
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Mining 2013 Peru

mining law Orihuela
Overview of the mining industry in Peru: What is the significance of the mining industry as a component of the national economy? Peru is a multi-metallic country that has one of the world’s largest mining reserves. It is the third-largest global producer of copper, silver, zinc and tin; and within Latin America, is
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Water in Peru

Water
Peru is a large producer of water due to its geographical configuration and extensive coast, including the Andes mountain chain, which with its high altitude and abrupt geomorphology has contributed to water distribution. This combination in addition to climatic factors has generated a large number of microclimates and ecosystems in the country. Today,
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