SEC Whistleblower Program: What Employers Need to Know
The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more
On July 11, 2019, FINRA provided additional guidance on obtaining extraordinary cooperation credit to supplement its prior enforcement guidance. FINRA Regulatory Notice 19-23, FINRA Investigations: FINRA Supplements Prior...more
Look at almost any corporate scandal; from Wells Fargo to Volkswagen to Uber and you inevitably see senior management making a similar statement: it was a (very) few bad apples, i.e. rogue employees, who engaged in the...more
Simply having a compliance program is no longer enough in today’s legal and regulatory climate. In the eyes of regulators, “check the box” or “paper” compliance programs are as good as not having one at all. Organizations...more
During recent speeches Deputy Attorney General Sally Yates and SEC Enforcement Division head Andrew Ceresney announced changes to the processes the DOJ and the SEC will use to decide if a company will receive “cooperation...more
The SEC, the DOJ and other regulators frequently encourage self-reporting and cooperation with law enforcement. Taking those steps will result in “cooperation” credit that will be reflected in the charging process or when...more
Attorneys Matt Allen and Todd Holleman give insights to the SEC Whistleblower Act and what employers need to know. ...more