Managing Whistlelbowers
10 For 10: Top Compliance Stories For the Week Ending August 23, 2025
Daily Compliance News: August 21, 2025, The Fabricated Evidence Edition
Adventure in Compliance: The Novels - The Valley of Fear, Whistleblowers and Corporate Compliance
Creativity and Compliance: Reinventing Compliance with Creativity: The Acteon I-Care Code
Moving Beyond the Usual Helpline Data
Podcast - Bring Out the Bad Stuff
Adventures in Compliance: The Novels - The Valley of Fear, Introduction and Compliance Lessons Learned
Episode 381 -- NAVEX's 2025 Annual Hotline Report
Compliance Tip of the Day: AI, Whistleblowing and a Culture of Speak Up
2 Gurus Talk Compliance: Episode 56 – The Grasshopper Edition
From the Editor’s Desk: Compliance Week’s Insights and Reflections from July to August 2025
Episode 379 -- Update on False Claims Act and Customs Evasion Liability
Everything Compliance: Episode 157, The Q2 2025 Great Women in Compliance Edition
10 For 10: Top Compliance Stories For the Week Ending July 19, 2025
2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Daily Compliance News: July 18, 2025, The Don’t Alter Docs Edition
Blowing the Whistle: What Employers Should Know About DEI & the False Claims Act
When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
TerraCom has been ordered by the Federal Court of Australia to pay an AUD7.5 million civil penalty for retaliating against a whistleblower in proceedings commenced by the Australian Securities & Investments Commission (ASIC)....more
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
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
On September 9, 2024, the US Securities and Exchange Commission (“SEC”) announced settled charges against seven public companies for violation of the whistleblower protection rule in connection with employment, separation,...more
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
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
As discussed in our December 15, 2023 client alert, the SEC has waged an aggressive effort to enforce alleged violations of the whistleblower protection rule. On September 9, 2024, the SEC announced settled charges resulting...more
Earlier this week, the SEC announced an enforcement sweep charging seven public companies with violating the whistleblower protections rule in various employment-related agreements. These charges reflect the SEC’s continuing...more
The Sarbanes-Oxley Act of 2002, also referred to as SOX or as Sarbox, is a federal statute that requires specific corporate recordkeeping measures as well as financial reporting. It was passed in the aftermath of several huge...more
The Sarbanes-Oxley Act (“Act” or ”SOX”) shields whistleblowers from retaliation for reporting any wrongdoing by publicly traded companies. Recently, in Murray v. UBS Securities, LLC, the U.S. Supreme Court evaluated the...more
In Murray v. UBS Securities, LLC the United States Supreme Court resolved a circuit split, holding that whistleblowers asserting retaliation claims under Sarbanes-Oxley must prove protected activity was a contributing factor...more
The United States Supreme Court recently heard oral argument in a case arising under the whistleblower provisions of the Sarbanes-Oxley Act of 2002 (SOX), presenting the question of who must prove intent in a whistleblower...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, 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
Regulatory Developments - SEC Adopts Amendments to Whistleblower Program Rules - On August 26, the SEC adopted two amendments to the rules governing its whistleblower program, which are covered under Section 922 of...more
Stable Road Enforcement Action Post Mortem: Lessons for the SPAC Market After Momentus Begins Trading - Stable Road And Momentus Close Business Combination. On August 11, Stable Road Acquisition Corp., a special purpose...more
Public company directors, who are under constant threat of claims, received welcome news earlier this month. On December 9, 2019, the U.S. District Court for the Southern District of New York ruled that corporate directors...more
This past week, the House Financial Services Committee considered and passed a few bills that would, if passed by the House, result in changes to the securities laws. ...more
The ARB recently affirmed the dismissal of a whistleblower retaliation claim under Section 806 of SOX, holding an employer is not a “contractor” covered by SOX simply because it was a party to a contract with a publicly...more
I have long articulated that companies that have robust compliance programs are more efficient, better run and more profitable organizations. ...more
A trial court in the Eastern District of Pennsylvania recently ruled that the whistleblower protections of the Dodd-Frank Act and Sarbanes-Oxley Act (“SOX”) do not necessarily apply to employees of private entities, even if...more
On August 10, 2016, the U.S. Securities and Exchange Commission issued a cease-and-desist Order and imposed remedial sanctions against a publicly traded company for including language in its severance agreements requiring...more
While the Dodd-Frank Act provides various protections to whistleblowers, federal courts have inconsistently interpreted who precisely qualifies as a whistleblower. In a much-anticipated opinion, the Second Circuit Court of...more
Various state and federal statutes exist to protect and compensate employees whose employers retaliate against them after they disclose certain fraudulent practices to the employers or government agencies. These are known as...more
The popular image of the American corporate whistleblower, as depicted in Hollywood box-office smashes such as The Insider and Michael Clayton, is a courageous hero who reports corporate wrongdoing, often at the risk of...more