Davis Polk counsel Bill Hochul authored “DOJ disclosure and whistleblower programs demand ‘prudent’ companies adopt an effective internal investigations strategy” in The Review of Securities and Commodities Regulation. In the article, Bill notes that, over the past year, federal prosecutors have issued new policies aimed at corporations that include voluntary self-disclosure guidelines as well as financial and other incentives for whistleblowers. In response, he argues that prudent businesses should create a robust internal investigations strategy, including when to hire outside counsel and how to handle whistleblower complaints.

The article was published in the June 5, 2024, edition of The Review of Securities & Commodities Regulation