News & Analysis as of

Whistleblower Protection Policies Enforcement

Pillsbury - Global Trade & Sanctions Law

UK Expands Whistleblower Protections to Bolster Sanctions Enforcement

On June 26, 2025, the UK government brought into force the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (the “2025 Amendment”), marking a notable development in the UK government’s sanctions...more

Cadwalader, Wickersham & Taft LLP

New Whistleblower Reward Schemes Would Dramatically Increase Enforcement Risk for UK Corporates and Regulated Firms

Quick read - It is all but inevitable that UK enforcement agencies will start paying for information about organisational misconduct.  In the US, whistleblower reward schemes have generated tens of billions of dollars in...more

Foley & Lardner LLP

NHTSA Adopts Final Rule to Formalize its Whistleblower Program under the Motor Vehicle Safety Whistleblower Act

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On December 17, 2024, the National Highway Traffic Safety Administration (“NHTSA” or “Agency”) adopted a final rule to formalize its whistleblower program under the Motor Vehicle Safety Whistleblower Act (Whistleblower Act). ...more

White & Case LLP

SEC Enforcement Year-End Overview

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2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more

Pillsbury Winthrop Shaw Pittman LLP

Key Areas to Consider Under the Updated Antitrust Division Corporate Compliance Guidelines

The revised Antitrust Compliance Guidelines expand their scope and provide critical insight into how the Department of Justice (DOJ) evaluates compliance programs—not only as tools to address criminal antitrust violations but...more

Bradley Arant Boult Cummings LLP

250 Whistleblower Tips: DOJ Official Discusses New Programs with Incentives for Dropping a Dime on Corporate Crime

On December 6, 2024, Principal Associate Deputy Attorney General Marshall Miller provided an update on the Justice Department’s (DOJ) corporate criminal enforcement efforts during his keynote address at the Practicing Law...more

Seward & Kissel LLP

SEC Announces Enforcement Results for Fiscal Year 2024

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On November 22, 2024, the SEC released its fiscal year 2024 enforcement statistics.  According to the accompanying press release, the SEC filed 583 total enforcement actions—431 of them standalone actions—while obtaining $8.2...more

Cozen O'Connor

Navigating the Future: Key Takeaways & Insights from the 2024 Securities Enforcement Forum Central

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One of the concerns following the Supreme Court’s ruling in SEC v. Jarkesy was that other agencies may face similar collateral attacks to its administrative proceedings. While the full impact of Jarkesy remains an open...more

Dorsey & Whitney LLP

DOJ Updates the Evaluation of Corporate Compliance Program Memorandum, Emphasizing Emerging Technologies, Data Analytics, and...

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On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs policy (the “Updated ECCP”), building upon the March 2023 updates. Since 2017, DOJ has offered...more

Pillsbury Winthrop Shaw Pittman LLP

From AI Doomers to E/Accs: How SB 1047 and the 38 AI Laws in California Are Shaping Future AI Law

California’s Safe and Secure Innovation for Frontier Artificial Intelligence Models Act is one of the first significant regulations of artificial intelligence in the United States that, if signed, would place liability on the...more

Seward & Kissel LLP

Recent SEC Enforcements for Violations of Whistleblower Protection Rule

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On September 9, 2024, the Securities and Exchange Commission (“SEC”) announced it settled enforcement actions against seven public companies for alleged violations of its whistleblower protection rule in their...more

Woods Rogers

CFPB Warns Employee Confidentiality Agreements May Violate Whistleblower Protections

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The Consumer Financial Protection Bureau (CFPB) recently issued the Consumer Financial Protection Circular 2024-04 warning financial institutions that broad employee confidentiality agreements may violate the whistleblower...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

CFPB Warns Employee NDAs, Confidentiality Agreements May Violate Whistleblower Laws

On July 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued guidance putting financial regulators and employers on notice that requiring employees to sign broad confidentiality or nondisclosure agreements that...more

Foley & Lardner LLP

California Dreamin’: Will SB-1047 Curb AI Innovation?

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On July 2, 2024 the California State Assembly Judiciary Committee passed SB-1047 (Safe and Secure Innovation for Frontier Artificial Intelligence Models Act), following its passage by the Senate on May 21, 2024. The bill aims...more

Davis Wright Tremaine LLP

CFTC Charges Trading Company With Market Manipulation and Whistleblower Protection Violations

On June 17, 2024, the CFTC's Division of Enforcement announced that it had reached a settlement with Trafigura Trading LLC ("Trafigura") over allegations that the firm manipulated oil derivatives prices while discouraging...more

American Conference Institute (ACI)

[Event] 18th Annual Conference on Anti-Corruption - June 18th - 19th, London, United Kingdom

Hosted by the C5 Group, the 18th Annual Conference on Anti-Corruption London will bring together the brightest minds in anti-corruption and compliance to review the most pressing multi-jurisdictional enforcement updates...more

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more

Alston & Bird

Carrots Aren’t Just for Companies: The SDNY’s New Whistleblower Pilot Program

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The U.S. Attorney’s Office for the Southern District of New York (SDNY) is taking aim at corporate criminal wrongdoing with a new whistleblower initiative. Our White Collar, Government & Internal Investigations Team breaks...more

Cornerstone Research

SEC Enforcement Activity: Public Companies and Subsidiaries—FY 2023 Key Trends

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The SEC noted cooperation by 69% of public companies and subsidiaries that settled in FY 2023, the third highest of any fiscal year in the Securities Enforcement Empirical Database (SEED). Of the cooperating defendants that...more

Freiberger Haber LLP

Enforcement News: SEC Charges Investment Advisor With Violating Whistleblower Protection Rule

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We have often written about the SEC’s whistleblower program and, in particular, the success of the program with respect to detecting and preventing violations of the federal securities laws. The success of the program...more

Allen Matkins

Has The SEC Put The Proverbial Horse Before The Cart?

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In a recently settled administrative proceeding, the Securities and Exchange Commission took the position that an employer took action to impede potential whistleblowers when as a condition of receiving separation pay, the...more

Bass, Berry & Sims PLC

Expect More Cyber-Enforcement under the False Claims Act

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Earlier this month, the White House released the National Cybersecurity Strategy Implementation Plan outlining specific “high impact initiatives” that the federal government will carry out to achieve its cybersecurity...more

Proskauer - Whistleblower Defense

District of NJ: Federal Courts Lack Jurisdiction to Enforce Preliminary Reinstatement Orders Under SOX

On April 19, 2023, the U.S. District Court for the District of New Jersey granted the defendant-employer’s motion to dismiss a complaint seeking court enforcement of a preliminary reinstatement order after determining that...more

White & Case LLP

How to Avoid Risk of SEC Whistleblower Rule Violations in Connection with Employee-related Documents

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On February 3, 2023, the US Securities and Exchange Commission ("SEC") announced that a public company agreed to pay $35 million to settle charges of, among other things, violations of the whistleblower protection rule.1...more

Dorsey & Whitney LLP

2023 Equal Employment Opportunity Trends in Litigation and Enforcement

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Data from 2022 portends a monumental year ahead for Equal Employment Opportunity (“EEO”) litigation and enforcement. Plaintiffs are filing class-based-employment claims in higher numbers than ever, and class actions involving...more

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