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Whistleblower Protection Policies Securities and Exchange Commission (SEC) Enforcement Actions

Bradley Arant Boult Cummings LLP

SEC Enforcement Leadership Discusses New Priorities and Expectations

On May 20, 2025, as part of the annual “SEC Speaks” program, the leadership of the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement publicly discussed the enforcement priorities under new Chairman Paul...more

Carlton Fields

Is SEC Whistleblower Program Topping Out?

Carlton Fields on

Since its establishment more than a dozen years ago, the SEC’s whistleblower program has grown substantially — in terms of the number of whistleblower tips received by the SEC, as well as the number and dollar amount of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Anti-Bribery and Corruption Risks Remain Despite FCPA Enforcement Pause

On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more

Moore & Van Allen PLLC

The Desk: January Issue

So, we’ll start off with our familiar and cherished Enforcement Roundup, touch on emergency funding for the CFTC’s Whistleblower Program, talk about the CFTC’s advisory on artificial intelligence, get you ready for updates to...more

Holland & Knight LLP

Ringing the (Jingle) Bell: Whistleblower Program 2024 Recap

Holland & Knight LLP on

Whistleblower programs are the gifts that keep giving to enforcement agencies, driving a record number of cases, sanctions and awards across multiple agencies. In this ninth installment of Season's Readings, we revisit some...more

Patterson Belknap Webb & Tyler LLP

Takeaways from the SEC Division of Enforcement’s FY 2024 Report

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

Moore & Van Allen PLLC

THE DESK: MVA’s Swaps and Derivatives Newsletter - December 2024

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With the CFTC still in the early stages of its fiscal year, in the month of November, we did not see a lot of action by way of publicly-released enforcement actions from the CFTC or enforcement-related public statements from...more

Cooley LLP

SEC Announces FY2024 Enforcement Results, Including Record-breaking Financial Remedies

Cooley LLP on

The Securities and Exchange Commission (SEC) recently announced its enforcement results for fiscal year 2024, during which the SEC obtained the highest amount of financial remedies in history—$8.2 billion, representing a 66%...more

Mitratech Holdings, Inc

Turning the SEC Enforcement Results into Opportunity: Historic Penalties Signal a Compliance Shift

The SEC’s fiscal year 2024 enforcement results signal a pivotal moment for U.S. capital markets. Despite a 26% decline in the total number of enforcement actions compared to 2023 (sitting at a total of 583 for this year), the...more

Cornerstone Research

SEC Enforcement Actions Against Public Companies and Subsidiaries Drop by 12% in FY 2024; Actions Still Up Nearly 5% Compared to...

Cornerstone Research on

The U.S. Securities and Exchange Commission (SEC) initiated 80 enforcement actions against public companies and subsidiaries in fiscal year 2024, marking a 12% decline from FY 2023 but still up nearly 5% compared to the...more

Woodruff Sawyer

SEC's Fall Festival: Lessons for Financial Services Companies

Woodruff Sawyer on

Every year, autumn brings hayrides, changing leaves, family gatherings, sweater weather, the chance to savor a cup of black tea by a roaring fire—and a raft of Securities and Exchange Commission (SEC) enforcement actions as...more

Cozen O'Connor

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

Cozen O'Connor on

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

Vedder Price

SEC Settles Enforcement Proceedings Against Adviser for Alleged Whistleblower Protection Rule Violations

Vedder Price on

On September 26, 2024, the SEC announced the settlement of administrative proceedings brought against a registered investment adviser for various alleged violations of Rule 21F-17(a) under the Securities Exchange Act of 1934,...more

Paul Hastings LLP

Public Company Watch: October 2024

Paul Hastings LLP on

In the October edition of our Public Company Watch, we cover key issues impacting public companies, including a recent SEC enforcement sweep, key takeaways stemming from the SEC’s recent adoption of EDGAR Next, two recent...more

Morgan Lewis

Securities Enforcement Roundup – September 2024

Morgan Lewis on

In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments and cases from September 2024. In September 2024 (the last month of the US Securities and Exchange Commission’s...more

Bradley Arant Boult Cummings LLP

Whistleblower Language in Separation Agreements Results in Large Settlements with SEC

On September 9, 2024, the Securities and Exchange Commission (SEC) announced settlements with seven public companies relating to their use of separation agreements that the SEC says violate whistleblower protection rules by...more

Fenwick & West LLP

SEC Settles Seven Whistleblower Protection Actions

Fenwick & West LLP on

On September 9, the SEC settled charges against seven public companies for violations of the whistleblower protection rule. According to the SEC’s orders, among other things, these companies violated Rule 21F-17(a) by...more

Troutman Pepper Locke

Prioritize Document Review for SEC Whistleblower Rule Compliance

Troutman Pepper Locke on

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

Fenwick & West LLP

Securities Law Update - September 2024

Fenwick & West LLP on

Welcome to the latest edition of Fenwick’s Securities Law Update. This issue contains updates and important reminders on...more

Foley & Lardner LLP

SEC’s Focus on Whistleblower Protection Practices Continues

Foley & Lardner LLP on

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

WilmerHale

SEC Continues Scrutiny of Provisions That Might Impede Whistleblowers

WilmerHale on

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

Dorsey & Whitney LLP

Companies Subject to U.S. Jurisdiction Should not Restrict Personnel from Being SEC Whistleblowers, or Receiving SEC Whistleblower...

Dorsey & Whitney LLP on

SEC rules prohibit taking “any action” to impede an individual from communicating directly with the SEC about a possible securities law violation, including by enforcing, or threatening to enforce, a confidentiality...more

Ballard Spahr LLP

Are Whistleblower Protection Violations the New SEC Sweep?

Ballard Spahr LLP on

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

Perkins Coie

Whistleblower Protection Remains SEC Priority

Perkins Coie on

Last week, the SEC announced settled charges against seven public companies for use of agreements that the SEC alleges have provisions that violate the whistleblower protection rule. Coincidentally, I recently recorded a...more

Ballard Spahr LLP

SEC Announces Settlements with Seven Public Companies for Violations of Exchange Act Whistleblower Protections in Employee and...

Ballard Spahr LLP on

The SEC has begun to bring enforcement actions against companies whose employment and client agreements could appear to infringe on the right to report cases in violation of Section 21f-17(a) of the Exchange Act. On September...more

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