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New Whistleblower Reward Schemes Would Dramatically Increase Enforcement Risk for UK Corporates and Regulated Firms

Quick read - It is all but inevitable that UK enforcement agencies will start paying for information about organisational misconduct.  In the US, whistleblower reward schemes have generated tens of billions of dollars in...more

DOJ Announces Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the U.S. Department of Justice (“DOJ”) officially unveiled its Corporate Whistleblower Awards Pilot Program (the “Program”). The three-year pilot program aims to broaden the range of corporate misconduct...more

Shadow Trading Expands Potential Insider Trading Liability in S.E.C. v. Panuwat

Insider trading generally refers to the trading of a company’s security based upon material non-public information (“MNPI”) about that company. But a recent litigation victory by the U.S. Securities and Exchange Commission...more

SDNY’s Whistleblower Pilot Program: Clarity for Individuals Could Cost Companies

On January 10, 2024, the United States Attorney for the Southern District of New York (SDNY) announced the creation of a Whistleblower Pilot Program (SDNY Whistleblower Program). While SDNY has long incentivized individuals...more

CFTC Enforcement − Aiding and Abetting Liability

Churchill is credited with saying “Never let a good crisis go to waste” at the end of WWII in reference to lessons learned in rebuilding the post-war world. The rolling collapse in crypto and digital assets’ markets, and...more

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