Nota Bene Episode 84: Organizational Integrity in the Post-Pandemic Enforcement Environment with Jonathan Aronie and Joseph Jay (Winter Repeat)

Sheppard Mullin's Nota Bene

This episode was originally published on June 3rd, 2020 as Episode 84.

The coronavirus pandemic has proven to be the most significant business crisis in global history. What will it take for multinational companies to aptly respond to the crisis while managing potential future harm from the Paycheck Protection Program (PPP) audits and investigations?

Michael is joined by two guests, Jonathan Aronie and Joe Jay, from Sheppard Mullin’s Organizational Integrity Group (OIG).

Jonathan Aronie is a partner in the Washington, DC office of Sheppard Mullin, and the co-leader of the firm’s Government Contracts and Internal Investigations Practice Group. In 2013, Jonathan was appointed by the U.S. District Court for the Eastern District of Louisiana to serve as the Federal Monitor over the NOPD Consent Decree, the most comprehensive Consent Decree in the country. He is the author of From Bourbon Street To The Board Room: Eight Aids to Sustaining Reform.

Joe Jay is a partner in the Government Contracts, Investigations & International Trade Practice Group in Sheppard Mullin’s Washington, D.C. office. Joseph’s practice encompasses a broad array white collar defense, corporate investigations, and international trade matters. His matters include defense of civil and criminal enforcement actions and investigations, compliance counseling and regulatory advice.

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What We Discuss in This Episode:

• What is the Organizational Integrity Group (OIG) and how does it help businesses?
• How has the coronavirus pandemic allowed the OIG to focus on what really matters when it comes to businesses responding in real-time to harm?
• What types of PPP audits and investigations will likely stem from the current pandemic?
• How will any investigations go beyond merely auditing funds that were disbursed? What else should businesses think about when carrying on with business activities under the PPP?
• What is the Defense Protection Act (DPA) and how might it affect enforcement of PPP spending?
• What types of questions are OIG clients asking of their counsel?
• One of the OIG’s First Principles guides businesses facing a potential crisis to “slow down the scene.” What does that entail?
• What goals are OIG counsel trying to achieve in what they call the legal “pre-mortem” portion of assessing a company’s needs?
• How important is it to “vet” any partners that your company plans on working with?

Resources:

• "Using “Prospective Hindsight” To Identify And Mitigate Risks During A Crisis," Organizational Integrity Group Blog, May 26, 2020