Since 2015, the SEC has brought nearly two dozen enforcement actions for violations of the whistleblower protection rules under Rule 21F-17(a) against employers for actions taken to impede reporting to the SEC. The bulk of these actions have focused on language in employee-facing agreements that allegedly discouraged such reporting. The
Whistleblower
Words Matter: Three Key Steps to Mitigate SEC Enforcement Risks Relating to Whistleblower Carveout Language
Since 2015, the SEC has brought nearly two dozen enforcement actions for violations of the whistleblower protection rules under Rule 21F-17(a) against employers for actions taken to impede reporting to the SEC. The bulk of these actions have focused on language in employee-facing agreements that allegedly discouraged such reporting.The SEC…
SEC’s Whistleblower Program Grants Fourth Largest Award in its History
By Kelly Curtis on
SEC Issues Largest Whistleblower Bounty Award Ever To One Individual
As we reported here, on May 5, 2023, the SEC issued an award of $279 million to a whistleblower. This is the largest award the SEC has issued to an individual whistleblower in the history of the SEC Office of the Whistleblower’s program.
Over $1 Billion Whistleblower Awards Paid to Date by the SEC
By Mee (Rina) Kim on
Last week, the SEC announced accumulated awards of over $1 billion paid to 207 whistleblowers since its first award in 2012. Over $500 million was awarded in fiscal year 2021 alone.
The SEC crossed the billion-dollar milestone with awards of $110 million and $4 million to two whistleblowers on September 15, 2021. The $110 million award marks the second-highest award to date and consists of $40 million stemming from an SEC case and $70 million for related actions by another agency.
July 2021 Update of the SEC’s Covered Actions for Potential Whistleblower Claims
By Mee (Rina) Kim on
On July 30, 2021, the SEC posted 14 Notices of Covered Actions, after which individuals have 90 calendar days to apply for a whistleblower award. As discussed in our prior post, the SEC publishes these Notices for cases in which the final judgment or order, either by itself or together with other prior judgments or orders in the same action issued after July 21, 2010, results in monetary sanctions exceeding $1 million.
In this post, we briefly survey the 14 Notices of Covered Actions from July 2021. (See our previous post on the SEC’s Notices of Covered Actions from June 2021.) Several of the alleged misconducts in the 14 Covered Actions also resulted in parallel criminal actions.
June 2021 Update of the SEC’s Covered Actions for Potential Whistleblower Claims
By Mee (Rina) Kim on
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. As discussed in our prior post, the SEC publishes Notices for cases in which the final judgment or order, by itself or together with other prior judgments or orders in the same action issued after July 21, 2010, results in monetary sanctions exceeding $1 million.
In this post, we briefly survey the six June 2021 Notices of Covered Actions.
Review of the SEC Whistleblower Program: At the Crossroads of Securities Law and Whistleblower Protection
By Mee (Rina) Kim on
Fiscal year 2020 marked the ten-year anniversary of the Dodd-Frank Wall Street Reform and Consumer Protection Act establishing the Securities and Exchange Commission’s whistleblower program. Since its inception through the end of FY2020, the SEC has awarded approximately $562 million to 106 individuals. Even a decade after it was created, the whistleblower program continues to break its own records; in 2020, the SEC issued several awards landing in the top 10 whistleblower awards of all time.