The last two months have seen the issuance of several awards from both the SEC and CFTC. As is often the case, these awards underscore the importance of timely disclosures.
Award Summary:
- SEC:
- October 1, 2024: $1.8 million to
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DOJ Whistleblower Program
In March of 2024, Deputy Attorney General Lisa Monaco, on behalf of the Department of Justice (“DOJ”), announced a new, three-year Corporate Whistleblower Award Pilot Program (the “Pilot Program”), designed to incentivize and reward certain individuals who report corporate wrongdoing. …
SDNY Whistleblower Pilot Program
Last Wednesday, the US Attorney’s Office for the Southern District of New York (“SDNY”) announced the launch of a whistleblower pilot program, designed to proactively uncover criminal conduct in the Southern District. As described in the press release, the…
Lundin PLLC’s Whistleblower Write-Up Now Includes a Database of SEC and CFTC Awards
By John Lundin
Over the last several months, we have been working behind the scenes to put together a database of final award orders issued by the SEC and CFTC. While the project remains a work-in-progress, it is at the stage where it…
SEC Frowns on Impeding Potential Whistleblowers: $10 Million Fine
Last Friday, the SEC announced that the agency had settled charges against D.E. Shaw & Co. LP, a New-York based investment advisor. Since 2011, and through at least 2019, D.E. Shaw had been in habit of requiring employees to sign…
Can a Lawyer be a Whistleblower?
By John Lundin
A question that we are occasionally asked concerns attorneys as whistleblowers. It’s a reasonable question—who is better positioned to know whether their employer (for in-house counsel) or client (external counsel) is following the rules? But with knowledge comes duty, and…
Supreme Court Denies Cert in Whistleblower Case
On May 30, 2023, the Supreme Court declined to review a challenge to an SEC award decision brought by an anonymous attorney who blew the whistle on a foreign bribery scheme. (Case No. 22-963.) The decision comes after the…
Whistleblowing and the U.S. Sanctions Against Russia
In response to the Russian invasion of Ukraine, the last two weeks have seen the imposition of several rounds of sanctions against Russian and Belarussian individuals, banks, and other business. How effective these sanctions are will depend entirely on their…