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Saturday, October 24, 2026

FCPA Compliance Report: Steph Holmes on Managing the Long Tail of Hotline Reports - JD Supra

In this episode, Tom Fox welcomes back his friend and colleague Steph Holmes of EQS Group. They take a deep dive into the “long tail” of hotline/whistleblower reports and why retaliation risk persists after an investigation closes, serving as a key indicator of organizational culture.

Holmes recommends starting with a retaliation-specific risk assessment, especially as EU whistleblower rules shift the burden to employers to prove they did not See more +

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