A Review Of Recent Whistleblower Developments - October 2014

• SEC Reverses Course and Awards Dodd-Frank Whistleblower $400,000
• SEC Makes First Whistleblower Award to a Compliance Professional
• SEC Announces Record Award of $30 Million to Foreign Whistleblower
• Second Circuit Adopts Broad Pleading Standard for Whistleblower Protection Under Sarbanes-Oxley Act, But Affirms Dismissal of Complaint
• Second Circuit Holds That Dodd-Frank Anti-Retaliation Provisions Do Not Apply Extraterritorially
• Eighth Circuit Ducks Deciding Whether Dodd-Frank Anti-Retaliation Provisions Require Reporting to the SEC

SEC Reverses Course and Awards Dodd-Frank Whistleblower $400,000

On July 31, 2014, the SEC awarded $400,000 to a whistleblower who had reported internally before providing information to the SEC. The award was unique because the SEC's Claims Review Staff had denied the whistleblower's claim on the grounds that the information provided had not been provided voluntarily because there had been a prior inquiry into the matter