On February 21, 2018, the Supreme Court of the United States ruled that the anti-retaliation provision of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act does not extend to an individual who has not...more
As we forecast in our August 2015 post, “The SEC’s Interpretative Guidance on Internal Whistleblowing Under the Dodd-Frank Act,” a federal court of appeals today issued a decision in line with the U.S. Securities and Exchange...more
On August 4, 2015, the U.S. Securities and Exchange Commission (SEC) issued an interpretive rule stating that whistleblowers who report misconduct internally—not just those who report to the SEC—are protected by the...more
2014 was a record-breaking year for whistleblowers, including both the U.S. Department of Justice’s prosecution of cases under the False Claims Act (FCA) and the U.S. Securities and Exchange Commission’s prosecution of cases...more
2/23/2015
/ Anti-Retaliation Provisions ,
Compliance ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Enforcement ,
Federal Contractors ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
Qui Tam ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
On June 16, 2014, the U.S. Securities and Exchange Commission (SEC) resolved its first whistleblower retaliation enforcement action. The SEC’s order against Paradigm Capital Management, Inc. is the first-ever enforcement...more
As we have discussed in earlier posts, the Administrative Review Board (ARB) has, over the last couple of years, issued a number of opinions signaling a decidedly employee-friendly interpretation of the whistleblower statutes...more
There has been much ink, real and digital, spilled on speculating about how the U.S. Securities and Exchange Commission’s (SEC) whistleblower program may affect companies’ internal compliance programs and the volume of...more
Over the past two years, we have seen the approach that the Administrative Review Board (ARB) has taken with respect to the scope and coverage of Dodd-Frank In almost every instance, the ARB has expanded the scope and...more
The importance of prompt and effective investigations of employee reports of wrongdoing has never been higher. Dodd-Frank and its changes to Sarbanes-Oxley have yielded a large increase in the number of reports—with much...more