Whistleblower Protection Blog

Truth-Telling at the 15th Ridenhour Prizes

The 15th Annual Ridenhour Prizes were held this year at the National Press Club in Washington, D.C.

In 1968, Vietnam War veteran Ron Ridenhour heard disturbing stories from fellow soldiers about a massacre that occurred during the war. Multiple first-hand accounts across platoons corroborated that American soldiers had been ordered to destroy a village and kill all its civilian inhabitants. After hearing about the massacre, Ridenhour wrote a letter to Congress urging for an investigation. The event Ridenhour exposed is now known as the My Lai Massacre. 

After the My Lai Massacre courts-martial, which led to only one conviction, Ridenhour went on to become an investigative journalist. He won the prestigious George Polk Award for Investigative Journalism in 1987 for his report on a New Orleans city-wide tax scandal. After his death, the Ridenhour Prizes were created to celebrate his spirit of truth-telling. 

On April 18, the 15th Annual Ridenhour Prizes were held at the National Press Club in Washington, D.C. The ceremony was held in collaboration with The Nation Institute, the Fertel Foundation, and the Mott Foundation. It was attended by members of the press as well as staff from the National Whistleblower Center.

This year, Tarana Burke of the #Metoo movement was awarded the Courage Prize; Lauren Markham, author of The Far Away Brothers was awarded the Book Prize; Joe Piscatella, director of Joshua: Teenager vs. Superpower was awarded the Documentary Film Prize; and Mayor Carmen Yulín Cruz Soto was awarded the Truth-Telling Prize. Former prizewinners include Howard Zinn, Gloria Steinem, Daniel Ellsberg, and Edward Snowden.

The spirit shared by Ron Ridenhour and the awardees can be summarized by a line from Mayor Cruz’s acceptance speech, in which she spoke of her call for aid after Puerto Rice was devastated by two hurricanes, and of inefficiencies in federal relief efforts that were causing civilian deaths.

“Playing along would have meant giving way to a false narrative, thus I told, for some, the inconvenient truth…we were dying, and they were killing us,” said Cruz. Cruz, along with the others honored with the Ridenhour Prizes, had all dared to speak inconvenient truths. 

Facebook Wildlife Trafficking Report Spreads Around World 

Ambassador Robert Whitehead, U.S. Embassy Togo, inspects the seized ivory (2014)

News outlets around the United States have picked up and expanded upon an Associated Press story about the whistleblower complaint to the Securities and Exchange Commission (SEC) lodged against Facebook. The story has also been picked up internationally, including publications in Asia, Europe, and Latin America.

The proliferation of this important story is indicative of both Facebook’s global reach and the worldwide nature of illicit wildlife trafficking. Facebook is the popular social media company in the world, with 2.2 billion active monthly users in countries all around the world. Wildlife trafficking is equally widespread, and nations around the world confront this scourge. Individuals should know they can report wildlife trafficking to an American attorney or U.S. authorities even if they are citizens or residents of another country.

The impact of illegal trafficking, facilitated by Facebook, has been devastating. More than 100,000 elephants were killed in a three-year period; Central Africa has lost 64% of its elephants. Rhinoceroses have fared no better: in 2007, only thirteen rhinos were killed by poachers. The last five years have seen over 1000 rhinos killed each year. The last northern white male rhino died last month, meaning extinction of the subspecies is imminent.

NWC Executive Director Stephen M. Kohn has emphasized that “Facebook is not an innocent bystander to these crimes.” He added “we’re seeking the strongest possible legal enforcement to stop wildlife trafficking that is threatening the extinction of numerous species. Wildlife is a treasure that benefits all of humankind and no nation, or groups of criminals have the right to threaten beloved creatures treasured by all of humankind. Traffickers are stealing from our heritage, our culture, and all children.”

Read more about the complaint here.

Read some of the press coverage below:

100 Days to National Whistleblower Day 2018!

Attendees at the 2017 National Whistleblower Day celebration.

Today marks the 100-day countdown to National Whistleblower Day, celebrated each year on July 30th.

National Whistleblower Day commemorates the passing of America’s first whistleblower law on July 30th, 1778. This visionary action, taken during the height of the American Revolution, stands as a testament to the importance of whistleblowing in U.S. history.

Each year since 2013, the Senate has passed a non-binding resolution marking July 30th as National Whistleblower Day. However, more needs to be done. Whistleblowers have played a critical role in upholding America democracy, and rooting out waste, fraud, and abuse. They should be celebrated and recognized for doing so.

National Whistleblower Center is current pushing for Congress and President Trump to pass legislation that will permanently recognize July 30th as National Whistleblower Day.

“Our Founding Fathers recognized the importance of defending whistleblowers, and so should we. Whistleblowers have made great contributions throughout American history, and should be honored and celebrated for their bravery,” said Mary Jane Wilmoth, a whistleblower attorney and chief financial officer of the National Whistleblower Center.

Executive Director of the National Whistleblower Center, Stephen M. Kohn, has given a TEDx Talk on the incredible story behind America’s first whistleblower law which can be viewed here.

Daniel Ellsberg On Whistleblowing

Daniel Ellsberg speaks on his experience blowing the whistle.

“What would you do if you were a young professional working at your dream job, and you discover that your employer was lying to the public, promoting a disastrous foreign war, and steadily expanding a weapons program that threatened to destroy human life on earth?”

Daniel Ellsberg faced this question himself multiple times in his life. He posed the same question to the audience during his April 10th talk at the Carnegie Endowment for International Peace, and in his new book, The Doomsday Machine. Ellsberg continued that he believes there are currently thousands of government employees looking at the prospect of nuclear war, whether or not they recognized this sentence as applicable to them.

In 1964, on Ellsberg’s first day of duty at the Pentagon, and seven years before he released the Pentagon Papers, President Lyndon B. Johnson and Secretary of Defense Robert McNamara began carrying out sorties in Vietnam. They told the public that the sorties were a limited retaliation to an unprovoked attack—statements which Ellsberg, due to his work, knew to be false. An ensuing series of lies paved the way for the passage of the Gulf of Tonkin Resolution, providing legal authorization for the Vietnam War.

At the time, it did not occur to Ellsberg to expose the deception. President Johnson was running against Senator Goldwater, who was campaigning on a platform of expanding war. But by staying silent, Ellsberg said that he was breaking the single oath he had taken as part of his job. As an employee with higher than top-secret clearance, he had signed many non-disclosure agreements. And yet, he had taken only one oath, one that was neither an oath of secrecy nor of loyalty to a particular individual: to “support and defend the Constitution of the United States against all enemies, foreign and domestic.”

Ellsberg had fought in the war as a marine, and initially believed the war was justified. However, his thoughts began to change during his time as a RAND Corporation employee when he was charged with compiling a report that is now known as the Pentagon Papers. After reading through thousands of documents, he realized that the Vietnam War was “wrongful and unjustified from the start.” With the rising death toll and the prospect of nuclear deployment, Ellsberg felt compelled to intervene. When his attempts within the Department of Defense led nowhere, he eventually took his copies of the report to the New York Times, which were subsequently published on June 13, 1971.

After the Papers were published, things went badly for Ellsberg. He faced a sentence of 115 years in prison. Nixon was re-elected with a landslide in 1968, and the bombings on Vietnam intensified. Then, the Watergate scandal happened. Nixon ordered members of the intelligence community to find psychiatric information to discredit Ellsberg, and the office burglaries eventually snowballed into one of the greatest political scandals in U.S. history. Nixon resigned and the Vietnam War came to an end.

Ellsberg offers no golden formula for whistleblowers. But he does recommend staying in one’s job long enough to collect sufficient evidence of fraud, waste, or abuse. In addition, Ellsberg believes the press has a vital role to play in uncovering and reporting on malfeasance. While whistleblower laws have improved since Ellsberg released the Pentagon Papers, it is deeply troubling that the sacrifices they must make to release the truth remain so steep. Ellsberg’s courage to come forward is an incredible testament to his character. That he needed to risk life imprisonment shows we must do more to protect brave whistleblowers.

When asked by a member of the audience when he thought a whistleblower should act, Ellsberg said that individuals should consider leaking, he said, “don’t do what I did. Don’t wait till the bombs are falling, or when nuclear war has already occurred in North Korea before you reveal or consider revealing estimates in the Pentagon.” He added that there are secrets which should be leaked and others which can only do harm, and that it is up to the good judgment of each whistleblower to tell the difference.

Ellsberg’s words are strangely prescient given the recent bombings on Syria, supposedly to target chemical weapons facilities. While he admits that the chance of whistleblowing affecting actual policy is slim, Ellsberg stated calmly that the chance remains greater than zero—and that it is worth risking one’s personal life just to increase that chance, if the stakes are high enough.

Good News for Pennsylvania Whistleblowers

Pennsylvania Supreme Court rules whistleblowers eligible to receive noneconomic compensation as rewards.

The Pennsylvania Supreme Court issued a big decision for whistleblowers in Bailets v. Pennsylvania Turnpike Commission, 2018 WL 1516785 (Pa. 2018). The Court ruled that noneconomic damages are compensable under Pennsylvania’s whistleblower law.

Ralph Bailets was a former Manager of Financial Systems and Reporting with the Pennsylvania Turnpike Commission. During his tenure, he became concerned about the government contractor Ciber Inc., which was politically-connected to leaders of the Commission. When competing for one infrastructure project, Ciber offered the most expensive bid, yet still was chosen for the contract. As Ciber struggled to perform the contract, Bailets took the issue to his supervisor. Bailet’s supervisor initially warned him that Ciber had friends in high places, and later advised colleagues that Bailet “should be kept on a short lease.” He was fired shortly thereafter.

At trial, Bailet was awarded $1.6 million in economic damages and $1.6 million in noneconomic damages. The Commission eventually appealed the reward to the Supreme Court, on the issues of whether noneconomic damages were permissible under Pennsylvania’s whistleblower law and whether $1.6 million in noneconomic damages was excessive.

Given that a stated purpose of Pennsylvania’s whistleblower statute was that whistleblowers be made whole for the losses they have suffered, the Pennsylvania Supreme Court’s decision—that the whistleblower should be eligible to receive noneconomic damages—only makes sense. The emotional costs of whistleblowing are significant. For a whistleblower to be made whole, as required by Pennsylvania law, such damages must be compensable.

The Pennsylvania Supreme Court should be credited for reading its whistleblower statute appropriately and the Pennsylvania legislature likewise deserves credit for putting in place a strong whistleblower law. Other states without such provisions should follow suit.

Congress Questions Facebook CEO on Wildlife Crime

In his testimony before Congress last week, Facebook CEO Mark Zuckerberg received tough questions from members of Congress about wildlife trafficking and the illegal ivory trade on his two-billion user social media site.

At the Joint Senate Committee Hearing, Senator Chris Coons (D-DE) referenced a recent Time article examining illicit wildlife crime on Facebook, stating, “wildlife traffickers are continuing to use Facebook tools to advertise illegal sales of protected animal parts.” Zuckerberg responded, “we’re going to have more than 20,000 people at the company working on security and content review.”

Yet, these new content review policies could be harmful if Facebook focuses only on deleting the illegal content. Instead, Facebook must work with law enforcement officials to combat illegal wildlife trade on its website.

Facebook provides a platform that facilitates communication for the illegal ivory trade. Representative Buddy Carter (R-GA) stated, “there’s so much ivory being sold on Facebook that it’s literally contributing … to the extinction of the elephant species.”

This is no exaggeration. Both the Asian and African elephant species are listed as endangered under Appendix I of the UN Convention on International Trade in Endangered Species (CITES). Central Africa lost 64% of its elephants within a decade. Furthermore, the world is currently facing the sixth mass extinction of animal and plant species. Zuckerberg admitted a lack of awareness on illicit ivory trade through Facebook. Once again, he mentioned Facebook’s increased efforts for content review. Yet, he still fails to acknowledge that Facebook profits from the illicit ivory trade and the loss of biodiversity.

In response to the Zuckerberg Hearings and Facebook’s profits from wildlife crime, Stephen M. Kohn, Executive Director of the National Whistleblower Center, stated that “Congress needs to ensure that the Securities and Exchange Commission (SEC) does its job. Permitting criminal activity on a company’s property will ultimately impact the value of the company stock, harming investors. The SEC cannot permit US investors to contribute the extinction of numerous threatened species including elephants, rhinos, and tigers.”

Senator Coons and Representative Carter should be commended for pressing Zuckerberg on these important issues. The international ivory trade and illegal wildlife trafficking jeopardize diverse ecosystems and species’ survival. The National Whistleblower Center’s Global Wildlife Whistleblower Program seeks to enlist whistleblowers to come forward and expose illegal wildlife trafficking. It is important that we push Facebook to eliminate wildlife trafficking on its site and urge Congress members to make sure online sites cannot be used as a hub for wildlife trafficking.

Those that know about the illegal wildlife trade can report it to an attorney here.

Delegation from South Asian Countries Visits the National Whistleblower Center

The international visitors delegation take a picture with presenters Michael Kohn, President of NWC, and Maya Efrati, an NWC legal fellow.

A delegation from countries including India, Maldives, Nepal, Pakistan, and Sri Lanka, visited the National Whistleblower Center (NWC) today to learn about U.S. whistleblower reward laws and their role in cracking down on fraud both domestically and internationally. The visit was facilitated by the International Visitor Leadership Program (IVLP), an initiative of the U.S. Department of State.

The presentation was led by NWC President Michael Kohn and NWC Legal Fellow Maya Efrati. In the presentation they demonstrated how whistleblower law is a powerful tool the government can leverage to combat fraud, increase transparency, and ensure accountability.

Questions from delegation members guided the conversation to a wide-range of subjects, including intelligence community and federal employee whistleblower protections; the role of NGOs in whistleblower advocacy and legislation; and NWC’s advocacy work based on information collected through Freedom of Information Act requests.

NWC hopes that the delegation enjoys their time in the U.S. and are able to use our lessons-learned in their own countries to implement more robust whistleblower protections.

Whistleblower Alleges Facebook Facilitates Wildlife Trafficking

An AP news story reports that an anonymous whistleblower has filed a complaint with the Securities and Exchange Commission (SEC) alleging that Facebook is facilitating and profiting from illegal wildlife trafficking on its social media platform. The anonymous whistleblower’s attorneys at Kohn, Kohn and Colapinto, LLP, (KKC) issued a press release and statements from the whistleblower. The full press release can be read here.

The whistleblower’s statements reveal their investigation into several online platforms, including Facebook, eBay, and Instagram. They state in the KKC press release:

“The amount of wildlife being traded on closed and secret groups on Facebook is horrifying. We saw multiple products: rhino horn, bear claws, tiger skins, reptiles, and tons and tons of ivory. At a time when the world is losing 30,000 elephants a year to poachers, the amount of ivory sold on Facebook is particularly shocking.”

“Through months of undercover work, we were able to identify more than one dozen distinct networks operating on Facebook. We traveled to Vietnam and Laos to meet with a number of ivory traders in person, confirming that they were actively selling ivory and other endangered wildlife products.”

In the AP story, Executive Director of the National Whistleblower Center, Stephen M. Kohn, states “Facebook is not an innocent bystander to these crimes.” He continues, “Facebook sold advertisements on the very pages the illegal ivory was being marketed.”

Illegal wildlife trafficking is a multi-billion dollar annual industry that threatens both human security and biodiversity. The National Whistleblower Center, through its Global Wildlife Whistleblower Program, will continue working to eliminate wildlife trafficking on online platforms.

TAKE ACTION: Demand that SEC Chairman Jay Clayton conduct an expedient and thorough investigation into the extent of Facebook’s involvement in wildlife crime.

Whistleblowers Vital to Eliminating Medicare Fraud

In a recent interview with the AARP, Attorney General Sessions took a strong stance against Medicare fraud. Sessions stated that it’s time to consider taking Medicare fraud as seriously as the war on drugs (certainly an issue Attorney General Sessions believes to be of paramount importance).

Medicare fraud is a serious issue. It is estimated that 10% of Medicare funds are lost to fraud and waste, totaling approximately $16.2 billion. This suggests that billions of dollars, which should be directed to funding health care for our seniors, are instead going to fraudsters taking advantage of American taxpayers and the elderly.

Whistleblowers are vital to eliminating Medicare fraud. They are best-situated to know about fraudulent and predatory practices. Chad Readler, the Acting Assistant Attorney General of the Justice Department’s Civil Division, has noted that “because those who defraud the government often hide their misconduct from public view, whistleblowers are often essential to uncovering the truth.”

The False Claims Act (FCA) is among the most powerful whistleblower laws on the books for uncovering fraud. It allows whistleblowers to bring cases as relators on behalf of the government, and assures them between 15% and 30% of funds collected from a favorable verdict or settlement. The growth in FCA cases has been critical for uncovering Medicare fraud, and the FCA would be even more powerful if fines were higher and reward percentages for whistleblowers were increased. Of the $3.7 billion collected by the government under the FCA in 2017, nearly $3.4 billion (or 92%) came from cases initiated by whistleblowers.

Unfortunately, and counter to the Attorney General’s rhetoric, the Justice Department recently issued a memo seeking to limit the number of FCA cases. In response, Stephen M. Kohn, the Executive Director of the National Whistleblower Center, stated that the “DOJ needs to spend more resources investigating and enforcing the law, not helping companies obtain dismissals of potentially valid cases.” He added, “this is a troubling sign and an indication of misplaced priorities.”

In the interview, Attorney General Sessions says “[n]ew laws could be helpful [to stop Medicare fraud],” and that “difficulty arises from how hard it is to identify the culprits in these cases and lack of resources to invest in these time-intensive cases.” The Attorney General’s statement here is accurate, yet incomplete. Federal law enforcement officials and prosecutors must contend with limited resources and there may be a role for new legislation in curbing Medicare fraud. But first the Attorney General should prioritize vigorously making use of already-existent laws. The January FCA memo should be shelved.

Quite simply, the DOJ will not be able to curb FCA litigation and Medicare fraud at the same time. The former is a critical tool for stopping the latter. If the FCA is reigned-in, Medicare fraud will explode. Whistleblowers need to be called into action, not placed on the sideline.

Whistleblower Tip Leads To 60-Ton Illegal Timber Seizure Outside Mumbai

The Hindustan Times has recently published a story on a 60-ton illegal timber seizure in Maharashtra, India that was initiated by a whistleblower. Since May 2017, over 500 tons of illegally-cut timber have been seized by authorities in the west-central Indian state. The value of the timber seized over the past 11 months is an estimated 20 million Indian rupees, or approximately $308,000 USD.

The tip-off led to not only the seizure of 30 tons each of teak and khair wood, but also the closure of an illegal saw mill that was functioning as a timber depot. The seizure demonstrates the powerful role whistleblowers play in combatting the illicit timber trade.

Whistleblowers have helped halt illegal logging in other parts of the world. In 2015, U.S. officials became aware of a massive shipment of illegal timber from a whistleblower tip. The wood came from parts of the Amazon that had been designated for protection. Because of the tip, the U.S. was able to stop the illegal shipment and the timber was seized and destroyed.

Illegal timbering is part of a global environmental crime epidemic. According to Interpol, illegal timber accounts for 15-30% of the global timber trade and is estimated to be valued at USD $51-152 billion annually. Illegal logging not only destroys ecosystems, but also threatens the rule of law. The UNODC has released a report outlining the linkage of corruption and wildlife crime, and has found those who participate in illegal logging are often able to do so through bribery of local public officials.

Because of the clandestine nature of the so-called “timber mafia,” and organized crime in general, whistleblowers are vital for stopping this kind of crime. Insiders are often better-positioned than law enforcement to detect criminal activity, and their information can help authorities efficiently uncover illegal activity.

Dr. Mahesh Patil, superintendent of the Thane rural police in Maharashtra, stated “there is need for more manpower from the forest department to control such activities as it is only going to increase.” Incentivizing and rewarding whistleblowers could be another solution to this problem. 20 million Indian rupees have already been recovered in illegal timber busts; a reward for the whistleblower might encourage more individuals to come forward in the future.

Rewarding and incentivizing whistleblowers has worked in other contexts. U.S. whistleblower reward laws have proven extremely effective in halting everything from customs fraud to insider trading on Wall Street. The tip-provider in Maharashtra came forward in good faith, as many whistleblowers do. More wildlife whistleblowers would come forward were monetary awards available.

DOJ Drops Case, IRS Whistleblowers to Receive $12.9 Million Award from Criminal Prosecution of Swiss Bank

Today, the U.S. Department of Justice officially dismissed their appeal of case Whistleblower 21276-13W and 21277-13W v. CIR, Case Nos. 17-1119 and 1120 (D.C. Cir.), marking a big win for IRS whistleblowers. Below is a statement from the whistleblowers’ attorneys.

The law firms of Zerbe, Miller, Fingeret, Frank & Jadav, PC (ZMF); Kohn, Kohn & Colapinto (KKC) and Robert Amsel, Esq. are pleased to announce today a key victory for tax whistleblowers with the filing of a joint stipulation for dismissal of the government’s appeal in the cases of Whistleblower 21276-13W and 21277-13W v. CIR, Case Nos. 17-1119 and 1120 (D.C. Cir.). The case was scheduled for oral argument on April 9, 2018 in the U.S. Court of Appeals for the District of Columbia Circuit.  It had pitted the U.S. Department of Justice and IRS against two whistleblowers whose information has led to $54.131 million in criminal penalties and civil forfeitures awarded against a major Swiss bank.  The DOJ and IRS were arguing that the tax whistleblower law did not apply to criminal tax cases that resulted in payments of fines and civil forfeitures.

The dismissal of the government’s appeals keeps in place the whistleblower’s win in the Tax Court decision of Whistleblower 21276-13W and 21277-13W v. CIR 147, TC 4 (2016) providing for a broad definition of “collected proceeds” – the basis for whistleblower awards in tax cases.   The whistleblowers had previously received an award of $4,474,000 based on the government’s collection from the Swiss bank of $20 million in restitution paid directly to the IRS for back taxes.  But the IRS refused to pay an award on the additional $54.131 million collected from the bank.

Based on the DOJ and IRS’s withdrawal of the appeal the whistleblowers will receive an additional award of approximately $12.9 million, as had been previously ordered by the Tax Court.

The appeal of this Tax Court victory for whistleblowers to the D.C. Circuit was being closely watched by whistleblowers and the tax community. Amicus briefs in support of the whistleblowers had been filed by former DOJ tax prosecutors who warned that limiting tax whistleblower rewards could have a crippling impact on criminal tax cases.  Senator Charles Grassley, the sponsor of the original tax whistleblower law, also filed an amicus brief in support of the whistleblowers.

Dean Zerbe of ZMF, the lead counsel for the whistleblowers in both the Tax Court case as well as the appeal to the D.C. Circuit said: “Today’s filing to dismiss the government’s appeal in Whistleblower 21276-13W is a win for everyone – for the whistleblowers who did so much to help the government in this case; as well as for the government by encouraging other whistleblowers to come forward with information about big-time tax cheats.  The only losers with today’s decision to dismiss the government appeal are tax crooks, Swiss bankers and Panama tax lawyers.”

Stephen M. Kohn of KKC, who served as co-counsel on the case, stated: “This decision is a green light for bankers with knowledge of criminal tax frauds to step forward and blow the whistle.  All whistleblowers should be encouraged by this decision of the government to dismiss its appeal.  It permits these two courageous whistleblowers to obtain a reward for turning in massive criminal tax frauds that had caused taxpayers to lose millions of dollars over the years and sets the precedent for future cases.  This decision, coupled with the recent clarification by Congress of the tax whistleblower law, is very good news for whistleblowers. The IRS is certainly interested in hearing from knowledgeable whistleblowers with good information about individuals and companies engaged in tax evasion.  If the case is successful, the government will pay rewards.”

Robert Amsel, who filed the original case on behalf of the whistleblowers, noted: “The whistleblowers were critical to the government’s success in this action against the taxpayer – providing vital knowledge and insight as well as one whistleblower twice putting herself in harm’s way to assist the government in getting critical recordings of witnesses.  As the government stated in Tax Court, ‘there was no plan B’ – but for the whistleblowers the government would never have been successful in bringing a $74 million-dollar action against a taxpayer engaged in tax evasion.”

Dean Zerbe stated: “I want to thank the Department of Justice lawyers, Ms. Teresa McLaughlin and Ms. Deborah Snyder of the Department of Justice Tax Division as well as Richard Hatfield, IRS Senior Counsel for their courtesy and professionalism in what truly is a win for both the government and whistleblowers.  I should especially note the tremendous work of my colleague Felipe Bohnet-Gomez at ZMF in this success as well as my co-counsels Stephen M. Kohn and David Colapinto at the Kohn, Kohn and Colapinto (KKC) law firm and of course my other co-counsel Robert Amsel of Miami, FL who has been invaluable from the very beginning for the whistleblowers.  Thanks also to Bryan Skarlatos of Kostelanetz & Fink, LLP, Nancy Gertner, Retired U.S. District Court Judge and Senior Lecturer at Harvard Law School and Jeffrey Neiman of Marcus Neiman & Rashbaum, LLP for their work on the impressive amicus curiae briefs they filed with the D.C. Circuit.”

Dean Zerbe added, “Most importantly, I join my co-counsels in thanking our clients—the whistleblowers—it is their hard work, patience and courage, working hand-in-glove with the government that brought us to this win today.”

Stephen M. Kohn also stated: “Today’s decision continues the good work of the two law firms – KKC and ZMF on behalf of tax whistleblowers — starting with the $104 million dollar award decision by the Whistleblower Office to Brad Birkenfeld and continuing with the wins in Tax Court for the whistleblowers here – 144 TC 15 (2015) and 147 TC 4 (2016).  Joint clients of KKC and ZMF have received approximately $145 million dollars in award determinations under the IRS tax whistleblower program. The tax whistleblower laws are certainly showing what can be accomplished by encouraging and awarding whistleblowers for coming forward – translating into hundreds of millions and now billions of dollars in tax revenues for the government – as well as substantive awards for whistleblowers.”

“Lastly, a special thanks to Senator Grassley (R-IA) and his never-ending work on behalf of all whistleblowers.  Senator Grassley sponsored the tax whistleblower law, ensured that the law was amended to close loopholes, and filed an amicus brief in the U.S. Court of Appeals trying to ensure that the whistleblowers obtained justice in this case.  Senator Grassley’s whistleblower laws have already resulted in over $50 billion in recoveries for the taxpayers and have held countless corporations and corrupt individuals who have tried to cheat the system accountable,” Kohn added.

  • U.S. Court of Appeals Order of Dismissal here.
  • National Whistleblower Center press release here.

Inside the Mind of a Whistleblower

Will Kramer knows what it means to be a whistleblower. As a former investigative staffer in the Senate, Kramer has ample experience working with whistleblowers. Later while serving as a health safety consultant, Kramer became one himself when he uncovered deeply disturbing conditions and improper handling of hazardous waste at several Greif Inc. plants. Kramer reported potential health, safety, environmental and securities violations to government regulators, members of Congress and the news media after the plants failed to address these issues. Now, as a law student, Kramer has written an important piece on the whistleblower mindset.

In the lead article for the Wisconsin Lawyer, Kramer examines what motivates whistleblowers and how attorneys can best work with whistleblower clients. Drawing upon his own experiences, academic research, and interviews with other whistleblowers and whistleblower attorneys, Kramer explains that “whistleblowers are primarily individuals who consider themselves to have a strong sense of morality and commitment to their organizations and feel compelled to correct what they perceive as a serious wrong against the public interest.”

Kramer’s interviews with whistleblowers like Fred Whitehurst, Jane Turner, Robert Maclean, and Bradley Birkenfeld show that “whistleblowers live in a world where morals and an organization’s stated values are so much more than mere slogans.” He also cites research that demonstrates “monetary reward was the least likely factor that would lead an employee to report wrongdoing outside their organization,” and a 1989 study found that whistleblowers “believe in absolute moral standards, individual responsibility, and a fierce commitment to upholding moral principles.”

David Colapinto, general counsel for the National Whistleblower Center and founding partner at Kohn, Kohn & Colapinto, also has found “the number one thing a whistleblower wants is the problem [they have identified] fixed.”

In following their moral code, whistleblowers often make enormous sacrifices. Kramer points out that all the whistleblowers said they would blow the whistle again, but these same whistleblowers would discourage others from doing the same. One whistleblower famously advised other whistleblowers to “be prepared to be ostracized, your career coming to a screeching halt, and perhaps even being driven into bankruptcy.” Ultimately, Kramer explains, “the risks of whistleblowing are enormous.”

Attorneys representing whistleblowers, lawyers on the other side of the table, and companies facing whistleblower complaints should all seek to better understand the whistleblower mindset. It is important to understand that whistleblowers are focused on correcting the harm, rather than a payout without reforms. Companies and agencies that have had the whistle blown on them need to understand retaliation won’t work: if anything, it will encourage the whistleblower to stop using internal channels to get the problem solved.

Kramer’s terrific article can and should be read in full, and is linked below.

Read the full article here.

Photo credit: Mike De Sisti / Milwaukee Journal Sentinel




Historic Win for Tax Whistleblowers at International Financial Institutions

DOJ withdraws appeal in criminal tax whistleblower case; whistleblowers to obtain US$12.9 million award

WASHINGTON, D.C. | MARCH 29, 2018—The U.S. Court of Appeals for the District of Columbia Circuit today will dismiss an appeal filed by the U.S. Department of Justice (DOJ) and Internal Revenue Service (IRS) challenging the right of whistleblowers to obtain a financial reward based on disclosing information that results in the criminal prosecution of tax evaders. The case concerned a major international financial institution that was sanctioned for illegally assisting U.S. citizens in evading taxes. The IRS had initially denied an award to the two whistleblowers.  The whistleblowers challenged the denial in Tax Court and prevailed.  However, the DOJ and IRS challenged this finding in the Court of Appeals. Today, at the request of DOJ, that appeal will be dismissed, and the two whistleblowers will become the first persons to obtain a whistleblower reward based on a criminal tax prosecution.

This case is the accumulation of over five years of effort by the NWC to overturn the IRS policy preventing whistleblowers from obtaining rewards based on criminal prosecutions.

“The most important tax evasion cases are criminal, and to exclude these cases from the whistleblower law would have had a devastating impact on enforcement,” said Stephen M. Kohn and Dean Zerbe, in a joint statement issued today by the National Whistleblower Center.  Kohn and Zerbe serve, pro bono, as the NWC’s Executive Director and Chief Policy Advocate.

“The dismissal of this appeal marks the end to a destructive policy which was undermining the tax whistleblower laws,” Kohn and Zerbe added.

Over the past five years Kohn and Zerbe have lead a national campaign to close the criminal loophole in the tax whistleblower law. This included:

  • During the rule making proceeding, providing testimony on behalf of the NWC to the Department of Treasury opposing the IRS rule which created the criminal loophole;
  • Publishing a comprehensive legal analysis in Tax Notes explaining why the criminal tax loophole was illegal and inconsistent with the clear requirements of the Tax whistleblower law;
  • Working with Congress to obtain a clarifying amendment explaining that whistleblowers who report criminal tax violations must be covered under the IRS whistleblower law;
  • Providing representation to the first whistleblowers who challenged the IRS rule in court.

The following statement was issued today by the attorneys representing the two whistleblowers.

Click here to view the statement.

National Whistleblower Center Continues Support of #MeToo Legislation

National Whistleblower Center (NWC), as a member organization of the Workplace Sexual Harassment Coalition, has signed a letter to Senate Majority Leader Sen. Mitch McConnell and Minority Leader Chuck Schumer to support the Congressional Accountability Act of 1995 Reform Act (H.R. 4924) which passed in the House of Representatives with bipartisan support last month. The Act, which seeks to improve workplace protections for Congressional staff, has gained broad public support due to the #MeToo movement.

In the letter, the Coalition makes recommendations as to the improvement of H.R. 4924. It also urges the Senate to include reforms passed in H. Res. 724. The Resolution requires that each “employing office” in the House establish an anti-discrimination and anti-harassment policy. It also calls for the creation of an Office of Employee Advocacy. The Office would assist employees with counsel and representation as they navigate Congressional Accountability Act processes.

This legislation, if implemented, would provide key protections for federal employee whistleblowers. It would also ameliorate the convoluted process currently in place for Congressional employees to report instances of sexual harassment, assault, or discrimination.

The Senate may pass these reforms as soon as this Friday, along with the $1.3 trillion spending bill that just passed the House this week.

Recommended reading:

National Whistleblower Center Meets with Top U.S. Department of Commerce Officials

This week the National Whistleblower Center (NWC) met with the U.S. Department of Commerce (DOC) General Counsel Peter Davidson and Senior Counsel James Uthmeier to discuss the implementation of whistleblower laws in their agency. NWC was represented by Executive Director Stephen M. Kohn, Managing Director of the Global Wildlife Whistleblower Program Scott Hajost, and Co-Chairperson of the Board Dr. Gina Green.

The meeting focused on how to combat illegal, unreported, and unregulated (IUU) fishing using whistleblower reward laws. Since the DOC has jurisdiction over the National Oceanic and Atmospheric Administration (NOAA), it is within their power to activate certain whistleblower reward provisions under U.S. wildlife laws, including the Lacey Act and Fish and Wildlife Improvement Act.

When speaking on IUU fishing, General Counsel Davidson commented that “Secretary Ross has a lot of interest in promoting U.S. aquaculture.” He continued, “combatting this illegal activity, it’s very similar to what we do on the trade front. It’s about unfair competition.”

The U.S. imports about 80% of its seafood. NOAA estimates that this leads to an annual seafood trade deficit of upwards of $13 billion USD. A 2014 study in Marine Policy shows that as many as one in three fish imported into the U.S. is caught illegally. In short, IUU fishing is a massive conservation and economic problem.

The implementation of whistleblower reward laws will serve to bolster the DOC’s 2018-2022 Strategic Plan. NOAA’s strategic goals and objectives include “enforc[ing] the nation’s trade laws and security laws.” Another goal includes “strengthen[ing] domestic commerce and the U.S. industrial base.” Combatting IUU fishing contributes to these objectives by cutting down on “unfair competition” against American industry and rebalancing the seafood trade deficit.

Mr. Kohn explained why leveraging U.S. whistleblower reward laws will prove to be a powerful tool in combatting illegal fishing. “Whistleblowers are key to stopping this kind of crime,” said Mr. Kohn. “Even with technological advances, the whistleblower is the human safety net when combatting IUU fishing. They are your eyes and ears on-the-ground.”

Mr. Kohn continued that implementing whistleblower reward laws does not cut into the DOC budget. In fact, sanctions gained from winning cases has the potential to recover millions of dollars for the government. Other laws with whistleblower reward provisions, such as the False Claims Act, have been tremendously successful in combatting criminal activity. In 2017 alone, whistleblowers filing under the False Claims Act recovered $3.4 billion in federal funds.

There is currently massive support within the U.S. for improving whistleblower protections in the Department of Commerce. NWC has already collected over 100,000 signatures on various petitions calling Secretary Ross to implement whistleblower reward laws in the DOC.

View the petitions here:

Bullet-Proof Qui Tam Case Settles

Attorney General Sessions Condemns Companies That Sell Defective Equipment to First Responders

The U.S. Department of Justice issued a press release late today announcing a settlement in a 13-year long False Claims Act case. Toyobo Co. Ltd. of Japan and its American subsidiary, Toyobo U.S.A. Inc., f/k/a Toyobo America Inc. (collectively, Toyobo), have agreed to pay $66 million to resolve claims under the False Claims Act that they sold defective Zylon fiber used in bullet proof vests that the United States purchased for federal, state, local, and tribal law enforcement agencies. 

The settlement was reached as part of a False Claims Act initiated by a whistleblower, Aaron Westrick, Ph.D. 

The attorneys for Dr. Westrick issued the following release following the DOJ’s announcement:

Bullet Proof Vest False Claims Act Case Ends in Victory for Whistleblower

Attorney General Sessions Condemns Companies That Sell Defective Equipment to First Responders

Washington, D.C. March 15, 2018.  The U.S. Department of Justice announced today that Japanese manufacturing company, Toyobo Co., Ltd., agreed to pay $66 million to settle allegations that it conspired to sell defective body armor to American police departments, federal law enforcement agencies and the U.S. military.  The settlement was reached as part of a False Claims Act initiated by a whistleblower, Aaron Westrick, Ph.D.

As required under the False Claims Act, Dr. Westrick will obtain a qui tam whistleblower reward of $5.77 million.  This award is designed to compensate Dr. Westrick for the damages he suffered and to incentivize other whistleblowers with evidence of fraud to report these crimes.

A detailed discussion on the national importance of this case is posted on The Whistleblower Blog.

Dr. Westrick, now employed as a tenured professor at Lake Superior State University in Sault Ste. Marie, Michigan and an active Michigan Deputy Sheriff, issued the following statement:

“I only wanted to stop the sale of unsafe Zylon vests to police officers, federal agents, and members of our Armed Services. I tried to convince my company to stop selling these vests.  They refused. I lost my job and career.  I have no regrets. I would blow the whistle again. The defective Zylon product was taken off the market and Toyobo (along with other companies) were held accountable. 

“I am proud that the United States joined in my False Claims Act case, and aggressively sought justice in this matter.”

In a statement released today by the DOJ, Attorney General Jeff Sessions said:

“Bulletproof vests are sometimes what stands between a police officer and death. Selling material for these vests that one knows to be defective is dishonest, and risks the lives of the men and women who serve to protect us. The Department of Justice is committed to the protection of our law enforcement officers, and today’s resolution sends another clear message that we will not tolerate those who put our first responders in harm’s way.”

Stephen M. Kohn, a partner in the law firm of Kohn, Kohn and Colapinto – who served as Dr. Westrick’s lead counsel said:

Dr. Westrick is a true American hero. He lost his job and career in the body armor industry by exposing Zylon safety risks. He provided the crucial documents and testimony justifying the removal of Zylon from the market, and compensation to states and the federal government due to the immoral sale of Zylon vests.

“The False Claims Act is America’s most important tool to fight fraud in government contracting.  It was enacted to protect and reward whistleblowers like Dr. Westrick, who sacrifice for the public interest, save taxpayers millions of dollars, and ensure that products sold to front-line responders are safe.”

Mr. Kohn also serves as the pro bono Executive Director of the National Whistleblower Center.

More information:

*Permission granted to reprint photo of Dr. Westrick.

Intelligence Community Whistleblower Ombudsman Fired

Intelligence community whistleblower ombudsman Dan Meyer has been fired. This is a disturbing and problematic move. It is particularly surprising, or perhaps cynically appropriate, that this occurred shortly after members of the intelligence community (IC) met with whistleblower rights organizations earlier this month.

Meyer had significant experience in whistleblower matters with the Department of Defense and served as an ombudsman in the Office of the Intelligence Community Inspector General (OIG).

Andrew Bakaj, also formerly of the OIG, stated, “Dan is a highly respectable individual with a lot of courage.” He added that Meyer advocated for a strong whistleblower program with a “two-fold purpose” of “encourag[ing] folks to come forward with information on a problem that the agencies need to know about,” and as a “mechanism to prevent people from making classified information public.”

Senators Chuck Grassley (R-IA) and Ron Wyden (D-OR) wrote to “express deep concern about the Office of Intelligence Community Inspector General.” Senator Grassley has previously asked that all documents be preserved in Meyer’s case.

NWC Executive Director Stephen M. Kohn attended a roundtable discussion with National Security Agency (NSA) Inspector General Robert Storch earlier this month and pointed out the serious deficiencies within the NSA’s current whistleblower law.

Current NSA whistleblower law does not provide for back-pay, lost wages, reinstatement of the whistleblower, statutory attorney fees, or judicial review of administrative decisions. Mr. Kohn advocated for informing whistleblowers of their rights under the False Claim Act and potentially arranging proffer agreements with individuals. The flaws within the NSA’s own whistleblower program apply across-the-board in the IC.

The Meyer firing demonstrates anecdotal evidence that the IC continues to conflate leakers with whistleblowers. Instead of firing intelligence officials for coming forward, they should be praised and rewarded for reporting NSA misconduct. The IC should be promoting people who understand this difference instead of firing them.

“No Right Without a Remedy”: Why NSA Whistleblower Protections Are Lacking

Earlier this month Stephen M. Kohn, executive director of the National Whistleblower Center, attended a roundtable discussion with the National Security Agency (NSA) Inspector General (IG) Robert Storch. The meeting served as an avenue for the IG to hear comments on the NSA’s whistleblower program.

In attendance was Andrew Snowdon, NSA whistleblower coordinator and Office of the Inspector General (OIG) counsel, as well as representatives from the American Civil Liberties Union, Project on Government Oversight, and Government Accountability Project, among others.

When explaining his commitment to strengthening whistleblower protections in the NSA, the IG stated, “there is no right without a remedy.”

Unfortunately, as the NSA whistleblower law currently stands, rights are only nominal. The law provides neither statutory attorney fees nor judicial review of Agency decisions. Additionally, there is no authorization for back pay, lost wages, compensatory damages, or reinstatement for the whistleblower. This is unlike other federal agencies’ policies covered under the Whistleblower Protection Act (WPA). Intelligence community agencies are excluded from WPA jurisdiction.

“There are bare minimum requirements for a real whistleblower program,” said Mr. Kohn. “Working under the current law raises serious issues as to whether the whistleblower can ever be truly protected,” he continued.

Mr. Kohn suggested that when informing whistleblowers of their rights, the NSA should make clear that 1) contractor employees have protections under the False Claims Act and 2) that a proffer agreement could be available to them. This would send a clear message that the NSA is interested in obtaining information, not targeting informants. It could also open the door to a discussion about immunity from criminal prosecution, a status that would encourage more individuals to openly and honestly come forward with information.

Mr. Kohn also strongly urged the IG to conduct an organization-wide climate survey to better understand knowledge and attitudes toward whistleblowing. Once this baseline is established, the program can set-up indicators to measure improvement.

Without strong, internal channels for reporting information in the NSA, the agency is incentivizing individuals to stay silent about possible problems. This is a lose-lose situation. There is great potential for whistleblowers and the NSA to cooperate, if protected avenues were available for reporting.

The NSA’s weak whistleblower protections are unsurprising. The intelligence community at-large has historically viewed whistleblowers as a threat, rather than a potential partner. In the wake of massive 21st century information leaks (e.g. the Chelsea Manning and Edward Snowden leaks), the Obama Administration Executive Order 13587 established the Insider Threat Program, whose mission is to “promote the development of effective […] programs within departments and agencies to deter, detect, and mitigate actions by employees who may represent a threat to national security.”

The Insider Threat Program has most certainly had a chilling effect on whistleblowing activity in the intelligence community. A compounding effect on whistleblowing is the Trump Administration’s aggressive stance on “leakers.” Attorney General Jeff Sessions’ comments and subsequent memo on the topic leave little doubt that the Administration is seeking to curb, not broaden, whistleblower protections.

NSA Whistleblower Coordinator Snowdon stated during the roundtable that “it is part of our job to distinguish between the two. Sometimes it’s difficult to tell.” Given the climate of hostility toward “leakers,” it is critical that the NSA does not conflate leakers with whistleblowers.

If the NSA Inspector General truly intends to strengthen whistleblower protections, he should make a public statement and testify before Congress that the OIG is committed to protecting whistleblower rights, and that it supports legislation to bolster those protections. Until such remedial measures the NSA legal framework, NSA whistleblowers are without rights.

NWC Joins SCOTUS Amicus Brief with FBI Whistleblowers

Earlier today, the National Whistleblower Center (NWC) joined a friend-of-the-court brief filed with the Supreme Court in support of FBI whistleblower John Parkinson’s petition for certiorari, seeking review of the Federal Circuit’s decision denying veterans’ preference-eligible FBI employees the right to raise whistleblowing as an affirmative defense in an appeal to the Merit Systems Protection Board (MSPB).

The amicus brief, filed on behalf FBI whistleblowers Michael German, Robert Kobus, Jane Turner, and Frederic Whitehurst, as well as the NWC and the Project on Government Oversight, details why the Department of Justice’s procedures for FBI whistleblowers are not an adequate substitute for a veterans’ preference-eligible FBI employee raising a whistleblower claim in an MSPB case.

Lt. Col. Parkinson was dismissed from the FBI and sought to raise whistleblower reprisal as an affirmative defense at his MSPB hearing. He was denied the opportunity by the MSPB, won an appeal of that denial before a Federal Circuit panel, but then lost on rehearing en banc. The Federal Circuit overturned, in part, a panel decision and determined that FBI whistleblowers may not raise whistleblower reprisal as an affirmative defense before the MSPB.

The amicus brief chronicles the long-winded paths to justice of four former FBI whistleblowers, including former FBI crime lab expert Dr. Frederic Whitehurst, who bravely blew the whistle on flawed forensic science at the FBI lab; former FBI agent Michael German, who reported the FBI’s illegal recording of conversations in violation of Title III wiretap regulations during a counterterrorism investigation; former FBI agent Jane Turner, who reported to the DOJ Inspector General that colleagues had stolen items from Ground Zero after the September 11, 2001 terrorist attacks; and retired FBI employee Robert Kobus, who worked at the FBI’s New York Field Office for 35 years and made a protected disclosure regarding some of his colleagues’ abuses of the FBI’s leave policy. Both Whitehurst and Turner hold leadership positions at the NWC.

Unfortunately, this is not the first time the Federal Circuit has issued a decision denying whistleblowers the rights intended by Congress. The Supreme Court should agree to hear this important case in order to correct the Federal Circuit’s dubious decision and to ensure that veterans who work at our foremost law enforcement agencies are fully protected when they blow the whistle.

Gregory Dubinsky, of Holwell, Shuster & Goldberg, who co-wrote the amicus brief, emphasized that “veterans make incredible sacrifices for our country, and we owe it to them to deliver on the promises Congress made in federal law to protect their rights when they face retaliation for blowing the whistle.”

Joshua Geltzer, of the Institute for Constitutional Advocacy and Protection (ICAP) at Georgetown University Law Center, and co-author of the amicus brief, remarked the Federal Circuit’s “decision to strip veterans now working at the FBI of protections they’d enjoy elsewhere in government flies in the face of Congress’s persistent efforts to protect such whistleblowers, and the Supreme Court should step in to correct it.”

David Colapinto, NWC General Counsel and partner in the law firm of Kohn, Kohn & Colapinto, who represented Whitehurst, Turner, and Kobus in their FBI whistleblower cases, said that the NWC is “very grateful that Holwell, Shuster & Goldberg and ICAP agreed to file the amicus brief” on behalf of NWC and the other amici.

Read the complete amicus brief here.

U.S. NGO Calls Upon GRECO to Intervene in Libel Lawsuit Filed Against Whistleblower Valery Atanasov

National Whistleblower Center states that Malta Gaming Authority lawsuit is an attack on freedom of speech and expression

WASHINGTON, D.C. | MARCH 8, 2018—The National Whistleblower Center (NWC), in cooperation with the European Center for Whistleblower Rights, has written a follow-up letter to a February 28thcommunication to the Group of States Against Corruption (GRECO), urging them to intervene in the libel lawsuit that the Malta Gaming Authority (MGA) has filed against former employee and whistleblower Valery Atanasov.

To read the follow-up letter to the GRECO Executive Secretary, please click here.

In the letter, NWC cites U.S. legal precedents that place limits on the lawful use of libel suits in order to ensure that the U.S. Constitution’s mandate of freedom of speech and expression is not undermined. Iturges the court(s) adjudicating Mr. Atanasov’s case to apply these rules in order to protect these same rights in Malta.

Mr. Atanasov blew the whistle on oversight irregularities and lack of enforcement while working at the MGA. He believed these irregularities could allow for money laundering and other financial crimes. Since reporting his concerns, Mr. Atanasov has been formally disciplined, suspended with a salary reduction, and fired from his job. Mr. Atanasov is now being sued by the MGA for defamation.

Under Article 14 of the Council of Europe’s Civil Law on Corruption, GRECO has the responsibility to monitor the implementation of the Convention of the Parties, including Article 9 which protects employees from unjustified retaliation from authorities should they, in good faith, report information on corruption.

Stephen M. Kohn, executive director of the National Whistleblower Center said, “the threat of a retaliatory libel lawsuit renders any whistleblower protection law a dead letter. Unless GRECO aggressively prevents the misuse of libel lawsuits to harass and intimidate whistleblowers, the right of employees to expose fraud and corruption will continue to be undermined in Europe.”

Mark Worth, executive director of the European Center for Whistleblower Rights and a member of the UN Expert Group on Whistleblowing said, “officials in Malta have ignored their own whistleblower protection law and taken aggressive civil and criminal actions against a public employee whose disclosures of misconduct have been irrefutably confirmed. This is shocking and unacceptable on all levels.”

Recommended reading:


HKLPA (@the_hklpa) Tweets

RT @NDDCEL: Ethics training is broken. Can #storytelling fix it? https://t.co/jSyvLL7HaT https://t.co/bWjHc5zQpV 4 weeks 15 hours ago
RT @EthicalSystems: "We are trying to give advice to organizations that are incredibly complex. When you put individuals together, they… https://t.co/Vs9bDKqorr 1 month 1 week ago
RT @sh_oldenberg: To Understand Complexity, Use 7 Dimensions of Ethical Thinking https://t.co/BAKgEWtIpk https://t.co/5LuaqJIiXc 2 months 1 week ago
RT @ComplianceXprts: 7 Things Every SME Exporter Needs To Know About Protecting Their Brand https://t.co/fpfGOQJQDw https://t.co/Z0VibE2IsB 2 months 2 weeks ago
RT @ComplianceXprts: Exporters Guide To Managing Compliance - Download our free ebook now!https://t.co/ypw6RwMrVE https://t.co/2NT9xereA7 2 months 2 weeks ago
RT @mikevolkov20: Episode 14 - What Every Compliance Officer Needs to Know About Data Privacy and the EU's GDPR - Corruption, Crime &… https://t.co/iZMjIPsBhs 3 months 3 weeks ago
RT @ComplianceXprts: What You Need To Know About Auditing And Risk Management In The Transport Industry https://t.co/IuMnS7mtgd 4 months 5 days ago
RT @EthicalSystems: Our 2017 End of Year Letter from @JonHaidt and @azishf https://t.co/ukjVe2Lqti "This is the time for the business… https://t.co/jUSNcY4gco 4 months 1 week ago
RT @ComplianceXprts: Inspection of Facilities and Sporting Venues - Due Diligence https://t.co/uKa3rYTJX0 https://t.co/EBXi6aBsW5 4 months 1 week ago
RT @ComplianceXprts: 14 Essentials For Your Compliance Management System https://t.co/FcQa8nRGWm https://t.co/Ru1oVnJelN 4 months 3 weeks ago