Michael Graham

Michael Graham

Proskauer Rose LLP

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SEC Denies Whistleblower Award Claim for Harbinger-Falcone Recovery

As recently reported by Ed Benson of Law 360, on July 4th, 2014, the United States Securities and Exchange Commission (the “SEC” or “Commission”) issued a final order that denied a whistleblower award claim on the $18 million...more

7/30/2014 - CEOs Harbinger Capital Partners LLC SEC Whistleblower Awards Whistleblowers

First SEC Whistleblower Bounty Award of 2014

On June 3, 2014, the SEC issued an order that awarded two whistleblowers $437,500 each pursuant to Rule 21F of the Securities Exchange Act. This Order marks the SEC’s first award of 2014, and eighth award since the program...more

6/9/2014 - Rule 21F SEC Whistleblower Awards Whistleblowers

SEC Denies Enforcement Action Award for Failure to Timely File Claim; Narrowly Defines “Extraordinary Circumstances” Exception

As reported by Rachel Ensign of the Wall Street Journal, the Securities and Exchange Commission (“SEC”) recently denied a whistleblower-claimant a Commission enforcement action award where the claimant failed to file timely...more

5/22/2014 - Compliance Enforcement Enforcement Actions Filing Deadlines Filing Requirements SEC

What’s The State Of The CFTC Whistleblower Program?

The SEC’s whistleblower program has received tremendous attention, but let’s not forget about the Commodity Futures Trading Commission’s (CFTC) whistleblower program, which also was created by Dodd-Frank. A recent article...more

10/29/2013 - CFTC Compliance Dodd-Frank SEC Whistleblower Protection Policies Whistleblowers

OIG Report On SEC Whistleblower Program: Praise, Suggestions & Conclusion That Private Right Of Action Would Be Premature

On January 18, 2013, the Securities and Exchange Commission’s (SEC) Office of Inspector General (OIG) released its report titled Evaluation of the SEC’s Whistleblower Program. The report presented a largely positive review of...more

2/6/2013 - OIG Private Right of Action SEC Whistleblower Protection Policies Whistleblowers

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