It is not the first whistleblower award under the Dodd Frank Act’s whistleblower bounty program but the “more than $14 million” award to an anonymous whistleblower that the SEC announced on October 1, 2013 is by far the largest so far...
Dodd-Frank added Exchange Act Section
21F(g)(5) and requires that SEC's Office of the Whistleblower to report to Congress
annually on the whistleblower program. It's due each October 30. I'm sure the
SEC wanted to be in compliance, so they...
Previously, I summarized the Securities and Exchange Commission’s implementing regulations of Title II of the JOBS Act , lifting the ban on general solicitation for offerings exempt under Rule 506 of Regulation D, which were finalized on July 10...
Here's a tip for potential Foreign
Corrupt Practices Act whistleblowers: travel expenses clearly fall within
A FCPA whistleblower is often
an employee or insider who often times assumes incorrectly that a bribe only
On October 30, 2013, the SEC announced another whistleblower bounty award under the Dodd-Frank whistleblower program. Although the size of this latest award ($150,000) is relatively modest compared to the recent $14 million award (about which refer here...
A critical component of the SEC’s whistleblower program is the anti-retaliatory provisions of Exchange Act Section 21F, added to the statute by the Dodd-Frank Act. To implement that provision the Commission promulgated two rules. The first, Exchange...
The number of whistleblower reports to the SEC increased again in the latest fiscal year, according to the annual report of the SEC whistleblower office. The report, which the SEC is required by the Dodd-Frank Act to provide to Congress annually, is entitled...
Hedge fund operators (politely called "Investment
Managers" on Wall Street) can make the plaintiffs' bar look like expensively
dressed social workers. The hedge fund industry is estimated to be a $2.5
trillion industry . Potential hedge...
In December 2010, the Ethics
Resource Center (ERC) released a White Paper entitled, " Blowing the Whistle
on Workplace Misconduct ." This White Paper report detailed several findings
that the ERC had determined through surveys, interviews...
This is the last three parts of an eight part series discussing new trends in SEC enforcement which impact corporate directors and officers and steps that can be taken to avoid future liability.
While increasing corporate fines is a hallmark of the...
The SEC brought its first enforcement action centered on corporate restrictions which could impact employee whistleblowers, deterring them from reporting to the agency. Specifically, the Commission alleged that a policy at KBR, Inc. which precluded the...
The fundamental question in National Federation of Independent Business v. Sebelius, Secretary of HHS, No. 11-393 (S.Ct. June 28, 2012), which addressed the constitutionality of the Affordable Care Act, was the scope of federal power within the United...
Companies in the United States and United Kingdom dealt with more litigation while regulatory investigations reached a five-year high, according to Fulbright's 9 th Annual Litigation Trends Survey .
After a one-year decline, litigation rose...