Businesses and organizations receiving stimulus package funds under the recently enacted American Recovery and Reinvestment Act of 2009 (the "Recovery Act") face new complex and high risk compliance responsibilities and potential for whistleblower complaints. Knowing how new substantive and procedural requirements will affect you and how to respond appropriately will be key to compliance and averting — or managing — risks and potentially high-profile litigation.
The Recovery Act provides nearly $500 billion in direct and trickle down spending. The Recovery Act affects an array of businesses, with particular emphasis on health, education, science, infrastructure, transportation, energy and environmental protection.
Every business and organization receiving Recovery Act funds directly or indirectly — as a contractor, subcontractor, grantee or recipient — should evaluate existing compliance programs and act to limit exposure to claims and legal proceedings for themselves and their executive personnel.
Beyond direct coverage, the bar of "best practices" has been raised to new heights, and even those who do not receive Recovery Act funds may want to reassess their compliance programs to assure that policies and procedures are current.
How whistleblowing can be a high-stakes problem to your business or organization and those entrusted with its management;
What the receipt of stimulus package covered funds changes for you and your business;
What you can expect if a whistleblower complaint is filed; and
How you can control your civil and criminal exposure by updating programs, policies and procedures to ensure they are sufficiently robust and effective.
This briefing has been approved for 1.5 hours of Ethics credit for Continuing Legal Education in New York.
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