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A Focus on Multinationals: Adding Enterprise Value Through Global Whistleblower Protocols and Promoting Employer Values

Client Alert | 1 min read | 11.12.21

Whistleblower activity—including new whistleblower laws—has increased in recent years; however, the number of internal whistleblower complaints has fallen. Internal whistleblower complaints are an opportunity for employers to correct misconduct, noncompliance, or other workplace problems as they happen. While this presents a challenge for employers, it is also an opportunity to reevaluate internal policies, training, and workplace culture. In this article, the second installment of a two-part series, Director of Global Corporate Compliance for Corning, Inc., Dan Christmas, along with Crowell’s Preston Pugh, Trina Fairley-Barlow, and Rachel Lesser, discuss strategies for maximizing the benefits and minimizing the risks of increased whistleblower activity. Part one of this series, available here, reviews the rise in whistleblower bounty laws and other laws designed to incentivize reporting.

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Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”...

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