Managing Whistlelbowers
Adventure in Compliance: The Novels - The Valley of Fear, Whistleblowers and Corporate Compliance
Compliance Tip of the Day: AI, Whistleblowing and a Culture of Speak Up
Compliance Tip Of the Day: Using AI to Transform Whistleblower Response
Whistleblower Challenges and Employer Responses: One-on-One with Alex Barnard
Episode 359 -- Review of the EU Whistleblowing Directive with Alex Cotoia and Daniela Melendez
False Claims Act Insights - Can DE&I Initiatives Lead to Potential False Claims Act Liability?
False Claims Act Insights - Some FCA Whistles Are Louder Than Others
The USDOJ Antitrust Division’s Compliance Guidance
Episode 353 -- 2024 FCPA Enforcement and Compliance Review
Workplace Investigation Protocols: One-on-One with Greg Keating
Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs
The Labor Law Insider - Whistleblower Breaks Details of NLRB Mail Ballot Election Abuse – Part II
Episode 335 -- The New DOJ Whistleblower Program
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
The Presumption of Innocence Podcast: Episode 37 - Vintage or Trendsetting? The SDNY's Whistleblower Pilot Program
Episode 321 -- Review of the EU Whistleblowing Directive wih Alex Cotoia and Daniela Melendez
Understanding the Whistleblower Pilot Program in the Southern District of New York
Episode 316 -- DOJ Announces New Whistleblower Policy
A recent article by Bloomberg Law highlighted a significant shift in the Securities and Exchange Commission’s (SEC) approach to whistleblower claims. The article, “Whistleblower Awards Slow to Trickle as SEC Raises Bar on...more
On November 22, 2024, the Securities and Exchange Commission (the “SEC”) published its enforcement results for fiscal year of 2024. The report shows a mixed result. The SEC only brought 583 actions in FY 2024, a 26% decrease...more
If you have not recently reviewed your company’s documents to ensure they comply with Securities and Exchange Commission (SEC) whistleblower protection rules, you should put it at the top of your to-do list. On September 9,...more
On September 9, 2024, the U.S. Securities and Exchange Commission (SEC) announced that it settled charges against seven public companies for alleged violations of Securities Exchange Act Rule 21F-17. According to the SEC,...more
On September 9, 2024, the Securities and Exchange Commission (SEC) announced settled charges against seven public companies for violations of certain whistleblower protections provided by Rule 21F-17 under the Securities...more
The Securities and Exchange Commission (SEC) continues to investigate companies for including language in their employment and separation agreements or retail client settlement agreements that potentially discourages...more
The Securities and Exchange Commission (SEC) recently settled charges against J.P. Morgan Securities LLC (JPMS) for impeding hundreds of advisory clients and brokerage customers from reporting potential securities law...more
Employers should check their confidentiality and severance agreements for a common oversight that, for some, is becoming a costly error. Recent enforcement activity by the Securities and Exchange Commission (SEC) of Rule...more
Despite a 50% increase in whistleblower tips over fiscal year (FY) 2022, the number of whistleblowers who received awards from the Securities and Exchange Commission (SEC) decreased significantly in FY 2023. This trend...more
DE Shaw, a prominent financial services firm, recently settled a retaliation case with the Securities and Exchange Commission (SEC) for a staggering $10 million. It was settled via an Administrative Order. This settlement...more
What: Twice this month, the Securities and Exchange Commission (SEC) announced settled actions against entities for violating SEC Rule 21F-17(a) related to language in their separation agreements, including one against a...more
Public companies should be mindful not to interfere with or retaliate against whistleblowers, and stretching is best reserved for the yoga mat, not the numbers in a company's public disclosures. So says the U.S. Securities...more
On February 3, the U.S. Securities and Exchange Commission (SEC) announced that video game developer Activision Blizzard, Inc. (Activision) agreed to pay $35 million to settle accusations that it violated whistleblower...more
Section 21F, titled "Whistleblower Incentives and Protection," is a set of provisions within the Securities Exchange Act of 1934 that govern, among other things, the rights and obligations of SEC whistleblowers and the...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include:...more
The Commodity Futures Trading Commission awarded approximately $200 million to a single whistleblower earlier this month based on the individual’s “significant contribution” to the success of a CFTC action and two Related...more
On August 5, the Securities and Exchange Commission (SEC) announced interim procedures effectively nullifying amendments to the SEC's whistleblower program adopted less than a year ago under former SEC Chairman Jay Clayton....more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business... SEC to Study Amended...more
The Situation: The SEC has brought another in a growing list of whistleblower cases critical of entities for potentially attempting to impede an individual from communicating with the agency. In July 2010, the Dodd-Frank Wall...more
Fiscal year 2020 marked the ten-year anniversary of the Dodd-Frank Wall Street Reform and Consumer Protection Act establishing the Securities and Exchange Commission’s whistleblower program. Since its inception through the...more
The highest award in the history of the SEC whistleblower program is issued to an employee who repeatedly reported misconduct internally before alerting the SEC. On October 22, 2020, the U.S. Securities and Exchange...more
On September 23, 2020, by a vote of 3 to 2, the U.S. Securities and Exchange Commission announced the adoption of a final rule implementing several changes to its whistleblower program, citing the need to “provide greater...more
On September 14, 2020, the SEC announced payment of more than $10 million to a whistleblower who provided original information to the SEC that led to a successful enforcement action....more
New efforts by states to incentivize whistleblowers financially underscore the importance of comprehensive corporate compliance programs that effectively address all internal reports of potential misconduct that may...more
On June 29, 2020, the Administrative Review Board (“ARB”) upheld the dismissal of a whistleblower retaliation complaint under Section 806 of the Sarbanes-Oxley Act (“SOX”) for failure to file within the 180-day statutory...more