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Internal Reporting Securities and Exchange Commission (SEC)

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

ArentFox Schiff

Investigations Newsletter: DOJ Launches Corporate Whistleblower Awards Pilot Program

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DOJ Launches Corporate Whistleblower Awards Pilot Program - On August 1, the US Department of Justice (DOJ) announced the details of its new Corporate Whistleblower Awards Pilot Program. According to the DOJ, the...more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

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Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

Oberheiden P.C.

A Handbook for SEC Whistleblowers

Oberheiden P.C. on

The U.S. Securities and Exchange Commission’s (SEC) Whistleblower Program was created in Section 922 of the Dodd-Frank Act of 2010, which amended the Securities Exchange Act to include a whistleblower provision. It has since...more

Troutman Pepper

Top 10 Tips for Drafting Whistleblower Compliant Arrangements

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Background - Under Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, Congress expanded protections for whistleblowers reporting possible violations of federal securities laws to the...more

NAVEX

SEC Office of the Whistleblower Annual Report to Congress – 3 Things You Need to Know

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On November 14, 2023 the Securities and Exchange Commission (SEC) released its annual Office of the Whistleblower Report to Congress for fiscal year 2023 (October 1, 2022-September 30, 2023). This report highlighted several...more

Jones Day

SEC Adopts Amendments to the Beneficial Ownership Rules

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In Short - The Background: On October 10, 2023, the U.S. Securities and Exchange Commission (the "SEC") adopted amendments to the rules that govern beneficial ownership reporting for investors, marking the first update to...more

Holland & Hart LLP

Three Takeaways From Recent SEC Enforcement Case

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The Securities and Exchange Commission (SEC) just announced a settled enforcement matter involving a public company and its CFO.  (AP File No. 3-21438)  The case presents three important takeaways for companies and...more

Fisher Phillips

Top 20 Questions to Ensure Your Compliance Program Helps You Minimize Corporate Criminal Risks

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Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more

StoneTurn

4 Critical Steps for Responding to Whistleblower Complaints

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In testimony before Congress earlier this year, U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler reported that the SEC received 46,000 complaints, tips, and/or referrals in fiscal year 2021, which nearly...more

Holland & Knight LLP

SEC Commissioner Signals Renewed Vigor for Up-the-Ladder Rule and Corporate Attorney Regulation

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Now, nearly 20 years after Congress passed the Sarbanes-Oxley Act, the congressional mandate to promulgate and enforce rules for corporate attorneys has gone largely unfulfilled. But all that may change. A recent speech by...more

Proskauer - Whistleblower Defense

SEC Proposes Amendments to Whistleblower Program Rules, Which May Lead to More SEC Tips

On February 10, 2022, the U.S. Securities and Exchange Commission announced two proposed amendments to its whistleblower program rules. As we previously reported, a closely divided SEC adopted a final rule implementing...more

Proskauer Rose LLP

Top 10 Whistleblowing and Retaliation Events Of 2021

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2021 was another blockbuster year in the whistleblowing and retaliation arena. The U.S. Securities and Exchange Commission Office of the Whistleblower has now issued in excess of $1 billion in whistleblower bounties. ...more

NAVEX

The SEC’s Record Whistleblower Reporting and Payouts Is a Wake-up Call for Organizations and Their Internal Reporting Systems

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On November 15th, the Securities and Exchange Commission (SEC) Office of the Whistleblower (OWB) released its 2021 Annual Report to Congress that reports staggering statistics for FY 2021 and should sound warning bells for...more

Proskauer - Whistleblower Defense

CA District Court: Dodd Frank Whistleblower Provision Does Not Apply Extraterritorially

On June 28, 2021, the United States District Court for the Northern District of California granted the Company’s Rule 12(b)(6) motion to dismiss after an executive claimed he was discharged in violation of the Dodd-Frank...more

Jones Day

SEC Awards $28 Million+ to Whistleblower for Tip Relating to 2018 FCPA Settlements

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On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more

Jones Day

SEC Awards More Than $500,000 to Individual Whistleblower Under "Safe Harbor" for Prior Internal Reporting

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SEC Whistleblower Awards to 40 individuals in 2021 surpass total awards in fiscal year 2020. On March 29, 2021, the Securities and Exchange Commission ("SEC") announced an award of more than $500,000 to a whistleblower who...more

NAVEX

A New Age of Accountability: Global Whistleblowing on the Rise

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In 2021, whistleblowers will come into their own in ways previously unseen. While the United States has had whistleblower protections for two decades, Europe and the Asia-Pacific region are setting new standards in...more

Proskauer - Whistleblower Defense

Bloomberg: SEC Receives Record Number of Whistleblower Tips From Remote Employees

A recent Bloomberg article reports that whistleblower complaints to the SEC have soared as employees have been working from home during the COVID-19 pandemic. According to the article, the SEC received 6,900 complaints in...more

Troutman Pepper

Companies Must Keep Pace With Whistleblower Reporting

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Despite the program's success, there remains considerable room for public companies and SEC registrants to improve their internal reporting apparatus—to build cultures that encourage whistleblowers to report internally...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

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On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

NAVEX

SEC Makes 2020 A Record Year for Whistleblowers. What Does It Mean for Compliance?

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This year is proving to be a record-setting year for whistleblowers. On October 22, the U.S. Securities and Exchange Commission announced it had awarded an unprecedented $114 million to a whistleblower who, the SEC says,...more

Jones Day

SEC Issues Largest-Ever Award of $114 Million to Individual Whistleblower

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The highest award in the history of the SEC whistleblower program is issued to an employee who repeatedly reported misconduct internally before alerting the SEC. On October 22, 2020, the U.S. Securities and Exchange...more

Proskauer - Whistleblower Defense

SEC Announces Record-Breaking $114 Million Award to Whistleblower

On October 22, 2020, the SEC announced an award of over $114 million to a whistleblower who, after reporting internally to their employer, provided the SEC with information and assistance that led to the successful...more

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