On May 3, 2022, the SEC’s Division of Corporation Finance (“CorpFin”) issued guidance reminding companies with disclosure obligations under U.S. securities laws to be cognizant of any disclosures that may be warranted as a...more
On December 14, 2020, the Securities and Exchange Commission announced an award of more than $300,000 to a whistleblower who uncovered potential securities law violations in connection with audit-related responsibilities. The...more
For the first time since its initial publication in 2012, the DOJ and SEC released an update to their 130-page guidance manual on the U.S. Foreign Corrupt Practices Act (“FCPA”). While not as highly anticipated as the first...more
The Securities and Exchange Commission has issued a reminder that when the business world returns to standard operations, enforcement actions will have a stinging bite. On April 16th the Commission announced that it will...more
In a closely followed case, on February 26, 2020, a District Court Judge in Connecticut granted Lawrence Hoskins’ motion for acquittal on the seven FCPA counts on which the jury convicted him. Hoskins was a UK citizen who...more
2/28/2020
/ Acquittals ,
Agency Relationship ,
Alstom ,
Bribery ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Indictments ,
Jurisdiction ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
The SEC’s most recent whistleblower awards highlight the importance of internal reporting to a company’s compliance program and especially how a company investigates and responds to such reports. On May 24, 2019, the SEC...more
On November 15, 2018, the Securities and Exchange Commission (“SEC”) released its annual report to Congress (“Report”) on the Dodd-Frank Whistleblower Program (the “Program”), under which eligible whistleblowers may receive...more
Today the Supreme Court held that an individual must report alleged wrongdoing to the Securities and Exchange Commission in order to qualify for protection from whistleblower retaliation under the Dodd-Frank Act.
While...more
In the course of one week, the United States Securities and Exchange Commission announced awards to three whistleblowers totaling more than $20 million under the Dodd-Frank Whistleblower Program.
On November 30, the SEC...more
On July 25, 2017, the SEC announced another whistleblower award – this one for almost $2.5 million. What sets this award apart from earlier awards is its recipient – “an employee of a domestic government agency.” The Order...more
On the last day of its current session, the Supreme Court announced it will consider whether the Dodd-Frank whistleblower protections extend to corporate insiders who blow the whistle on their employers by reporting the...more
A five-year statute of limitations applies to actions by the Securities and Exchange Commission for disgorgement, the U.S. Supreme Court ruled today. The decision imposes a significant new limit on the SEC’s ability to seek...more
In the past two weeks, the United States Securities and Exchange Commission announced the first two awards it has granted to whistleblowers under the Trump administration.
On April 25, 2017, the SEC announced an award of...more
On March 8, 2017, the United States Court of Appeals for the Ninth Circuit created a new wave in the ongoing debate over the scope of Dodd-Frank’s anti-retaliation or “whistleblower” protections. In Somers v. Digital Realty...more
On November 15, 2016, the Securities and Exchange Commission (“SEC”) released its annual report to Congress on the Dodd-Frank Whistleblower Program (the “Program”). As noted in prior reports, the past year has been historic...more
On November 14, 2016, the United States Securities and Exchange Commission announced an award of at least $20 million to a whistleblower for providing information that initiated a successful investigation and enforcement...more
The Securities and Exchange Commission (SEC) recently announced a settlement with a Nevada corporation of its first stand-alone whistleblower anti-retaliation case. On September 29, the SEC announced a $500,000 sanction...more
On Wednesday September 28, 2016, the SEC announced Jane Norberg as the new chief of the SEC’s Office of the Whistleblower. Ms. Norberg said: “It has been an honor serving in the roles of deputy and acting chief and working...more
The Securities and Exchange Commission (“SEC”) recently announced that two companies agreed to pay penalties of more than $500,000, combined, for illegally requiring employees to waive their rights to monetary awards from the...more
On June 9, 2016, the United States Securities and Exchange Commission announced its second largest award under the agency’s Dodd-Frank Whistleblower Program. This is the largest such award issued since the SEC issued a $30...more
A federal appellate court recently held that the five-year statute of limitations in 28 U.S.C. § 2462 applies to actions by the Securities and Exchange Commission for declaratory relief and disgorgement. The decision extends...more
In the past week, the SEC has issued two multimillion dollar awards to whistleblowers. The announcement of two significant awards in quick succession suggests that the “significant uptick” in in the number of tips noted by...more
The Commodity Futures Trading Commission (“CFTC”) recently announced the largest ever award under its Whistleblower Program created by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The whistleblower...more
So you want to use the government’s EB-5 Immigrant Investor Program (“EB-5 Program”) to raise cash? Be aware that the SEC will be looking over your shoulder to determine whether you are acting as an unregistered broker-dealer...more
On Tuesday, March 8, 2016, in conjunction with announcing a recent $2 million whistleblower award, Sean McKessey, Chief of the Office of the Whistleblower, stated that the SEC continues to see “a significant uptick” in the...more