The Securities and Exchange Commission has voted to adopt numerous amendments to the rules governing its whistleblower program. See https://www.sec.gov/news/press-release/2020-219
The whistleblower program serves as a significant tool for the Commission to encourage individuals to come forward with information regarding suspected security fraud. As set forth in the SEC’s press release, “The amendments to the…
As the country faces a wave of COVID-19 closure orders, individuals are being encouraged to report violations. Hypothetically, these reports could originate from just about anyone – employees, employees’ family members, customers, neighbors, the general public. Given the wide range of potential complainants, these reports may not always be based on first-hand observations.
When investigating…
Too often, internal investigators mistakenly conclude that their reports are for the exclusive review of decision-makers. Sometimes, this may be true. However, more often than not, there are two audiences of which an investigator should be mindful – a primary audience and a secondary audience.
The primary audience is the immediate recipient(s) of the report. …
