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DOJ Updates Criteria for Review of Corporate Compliance Programs, Emphasizing AI Issues

On September 23, the Department of Justice updated the document it uses to evaluate a corporation’s compliance program in the context of wrongdoing by the corporation – the Evaluation of Corporate Compliance Programs, or...more

Incentivising Whistleblowers: What Does the Future Hold in the UK and the US for Whistleblower Protection and Incentivisation?

In the UK, it has not historically been part of the fabric of our legal and regulatory system to pay whistleblowers who provide evidence to authorities who are investigating potential breaches of law or regulation....more

SEC Issues Rare Whistleblower Award to Audit Professional

On December 14, 2020, the Securities and Exchange Commission announced an award of more than $300,000 to a whistleblower who uncovered potential securities law violations in connection with audit-related responsibilities. The...more

Emerging Themes in Financial Regulation 2020

Under the Senior Managers and Certification Regime (“SMCR”), firms are required to identify and report to the FCA any instances of disciplinary action taken in relation to conduct that would amount to a breach of one of the...more

Another Record Breaking Year for the SEC Whistleblower Program

On November 15, 2018, the Securities and Exchange Commission (“SEC”) released its annual report to Congress (“Report”) on the Dodd-Frank Whistleblower Program (the “Program”), under which eligible whistleblowers may receive...more

Supreme Court Narrowly Construes the Definition of a Whistleblower Under Dodd-Frank

Today the Supreme Court held that an individual must report alleged wrongdoing to the Securities and Exchange Commission in order to qualify for protection from whistleblower retaliation under the Dodd-Frank Act. While...more

Supreme Court Will Review Scope of Dodd-Frank Whistleblower Protections for Internal Reports

On the last day of its current session, the Supreme Court announced it will consider whether the Dodd-Frank whistleblower protections extend to corporate insiders who blow the whistle on their employers by reporting the...more

SEC Announces First Whistleblower Awards Under New Administration

In the past two weeks, the United States Securities and Exchange Commission announced the first two awards it has granted to whistleblowers under the Trump administration. On April 25, 2017, the SEC announced an award of...more

SEC Targets Whistleblower Retaliation

The Securities and Exchange Commission (SEC) recently announced a settlement with a Nevada corporation of its first stand-alone whistleblower anti-retaliation case. On September 29, the SEC announced a $500,000 sanction...more

CFTC Announces $10 Million Whistleblower Award, Its Largest Award Yet

The Commodity Futures Trading Commission (“CFTC”) recently announced the largest ever award under its Whistleblower Program created by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The whistleblower...more

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