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Another Court Breathes Life Into SOX Protected Activity Defenses

The gap between how federal courts and the Administrative Review Board (ARB) define protected activity under Section 806 of SOX widened further this month when the U.S. District Court for the Southern District of New York...more

12/20/2012  /  Sarbanes-Oxley , Whistleblowers

Top 10 Ways To Minimize Whistleblower Risks

Here are the TOP 10 STEPS public and private employers should consider taking to minimize the risk of whistleblower retaliation claims and build defenses where litigation is unavoidable....more

Sixth Circuit Allows Key Defenses To SOX Whistleblower Claims That ARB Rejected

In a SOX whistleblower decision, the U.S. Court of Appeals for the Sixth Circuit embraced a number of employer-favorable legal standards that the Administrative Review Board (ARB) recently rejected....more

A Clear Illustration of How HR & Employment Law Best Practices Intersect With Compliance

On November 14, 2012, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) jointly issued a guide to the Foreign Corrupt Practices Act (FCPA) titled: A Resource Guide to the U.S. Foreign Corrupt...more

FINRA Rule Amended: Whistleblower Claims Not Subject To Mandatory Arbitration

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd Frank) amended the whistleblower provision in Section 806 of the Sarbanes-Oxley Act of 2002 (SOX) to state that pre-dispute arbitration agreements that...more

SEC Annual Report: Thousands of Tips, One Award & Minimal Transparency

In its Annual Report on the Dodd-Frank Whistleblower Program (Report), the SEC has revealed that it has received 3,001 tips during its 2012 fiscal year (the first year of this program), and it paid out its first award to a...more

ARB Says “Convenience Leave” Letter Does Not Trigger SOX Statute of Limitations

On August 31, 2012, the Administrative Review Board (ARB) of the U.S. Department of Labor (DOL) liberally interpreted the standard governing when the SOX statute of limitations clock starts ticking, ruling that a letter...more

OSHA Announces ADR Pilot Program

The Occupational Safety and Health Administration (OSHA), which is charged with enforcing the whistleblower protection provisions in 22 separate statutes – ranging from Section 806 of the Sarbanes-Oxley Act of 2002 to...more

The Fight Isn’t Over: Employers Should Keep Battling The Definition of “Whistleblower” Under Dodd-Frank

The “Securities Whistleblower Incentives and Protection” section of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“DFA”) is an integrated scheme designed to encourage individuals to complain to the...more

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