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internal reporting mechanisms. These problems help drive whistleblowers and moreonerous and costly settlement terms. The compliance requirements being imposed bythe government enforcers in whistleblower cases tell responsible managers what isexpected. Documented action of relevant changes to a company’s compliance effortsbased on reported cases send an important message to enforcers that can greatlyassist in driving a more favorable outcome to an investigation triggered by awhistleblower.F. Focusing Audits and MonitoringEffective management of whistleblower risk includes focused audit and monitoring ofthe priority risks faced by a given business. This documented activity, tied to theevaluation of internal reports, and annual compliance work plans, helps demonstrategood faith efforts to operate in accordance with applicable law. In the competition forthe resources available today for compliance, audit, and monitoring must focus on redflag issues identified internally and through other sources. Success in avoidingwhistleblower claims and enforcement requires the correct prioritizing and monitoring ofkey risk areas.G. Using Disclosures to Preempt WhistleblowersIn every business setting, it is expected that compliance problems will be uncovered.Many problems will be caught early enough to head off a potential whistleblower andenforcement risk. In some cases, for example, when claims or certifications have beenincorrectly but unintentionally submitted, the company is able to make corrective filingsor disclosures that cut off risk. In other cases, such as when possible bribery or other21