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On May 25, 2011, the US Securities and Exchange Commission (the "SEC"), in a 3 to 2 vote along party lines, adopted rules implementing Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act" or the "Act"), which requires the SEC to establish a program to pay awards to eligible whistleblowers reporting federal securities law violations.

In this article, the authors identify four recent trends in the SEC's whistleblower program: a significant uptick in whistleblower bounties; awards for mid-investigation tips; the more lenient "objectively reasonable" standard for whistleblower protection from retaliation; and a continued focus on confidentiality agreements.

On February 3, 2023, the US Securities and Exchange Commission (SEC or Commission) announced that video game developer Activision Blizzard, Inc. (Activision) agreed to pay $35 million...

On Friday, the SEC, without holding an open meeting, adopted two amendments to the whistleblower program that had been proposed in February. The vote was three to two.

The SEC amended its whistleblower program with the goals of (i) providing greater transparency to whistleblowers, (ii) properly incentivizing whistleblowers and (iii) awarding whistleblowers to the "maximum extent appropriate."

According to a February 25, 2015 Wall Street Journal report, in recent weeks the SEC has sent requests to a number of companies seeking years of nondisclosure agreements, employment contracts and other documents as part of an agency probe into the potential silencing of corporate whistleblowers.

The US Securities and Exchange Commission (SEC or Commission) had an active fourth quarter, rounding out a record-breaking calendar year that saw several significant enforcement actions and regulatory developments.

The SEC is now in the process of writing the rules for implementation of the much-ballyhooed whistleblower law enacted last summer as part of the Dodd-Frank financial overhaul bill (the "Act").

In light of the SEC's recent enforcement activity involving Rule 21F-17, this post aims to provide a brief overview of the rule's purpose, history and enforcement evolution.

As we have discussed in previous posts, Section 922 of the Dodd-Frank Act established a whistleblowing program under the auspices of the SEC.

Most notably, Indiana's Securities Division awarded $95,000 to a whistleblower based on civil penalties imposed on a multinational financial services firm.

As the Securities and Exchange Commission's whistleblower program continues to build momentum, there is no question that companies are facing increasing numbers of reports of possible misconduct, both through internal reporting mechanisms and through whistleblower complaints and tips filed directly with the SEC.

Arnold & Porter's Jane Norberg and Daniel M. Hawke discuss the SEC's Annual Report to Congress on it's Whistleblower Program and highlight the key takeaways...

On June 30, 2021, the SEC posted six Notices of Covered Actions, for which individuals have 90 calendar days to apply for a whistleblower award.

The SEC announced an expected award of $475,000 to $575,000 to a former company officer "who reported original, high-quality information about a securities fraud that resulted in an SEC enforcement action with sanctions exceeding $1 million."

Arnold & Porter's Jane Norberg was recently featured on the "Great Women in Compliance" podcast. With her extensive experience as a former Chief of the Office of the Whistleblower...

The U.S. government has recently paid substantial awards when the CFTC awarded $290,000 to a whistleblower for providing valuable information about violations of the Commodity Exchange Act.