On May 17, 2016, the Securities and Exchange Commission (SEC) announced that it would award between $5 million and $6 million, the third-highest award ever, to a whistleblower who provided information detailing securities violations committed by the whistleblower’s former employer. Under the so-called “bounty” provision of the Dodd-Frank Act, the SEC is authorized to award
Corporate Compliance
Greater Emphasis On Corporate Compliance Programs
Early in 2015, the FBI launched a new program aimed at routing out foreign bribery in which it established three dedicated international corruption squads, based in New York City, Los Angeles, and Washington, D.C. The FBI reported that members of these three squads—agents, analysts, and other professional staff—have a great deal of experience investigating white-collar…
SEC Action Impacts Employer Confidentiality Agreements
The Securities and Exchange Commission recently settled its first administrative proceeding and enforcement action under the Dodd-Frank Act involving an employer’s use of a form confidentiality agreement. The SEC found the agreement, which prohibited employees from discussing aspects of internal investigations without prior law department authorization, could interfere with the employee’s ability to communicate with…