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SEC whistleblower bounties: ten things companies can do right now to stay ahead

William R. McLucas (Partner with Wilmer Cutler Pickering Hale and Dorr LLP, Washington, District of Columbia, USA)
Laura S. Wertheimer (Partner with Wilmer Cutler Pickering Hale and Dorr LLP, Washington, District of Columbia, USA)
Andrea J. Robinson (Partner with Wilmer Cutler Pickering Hale and Dorr LLP, Boston, Massachusetts, USA)
Mary Jo Johnson (Partner with Wilmer Cutler Pickering Hale and Dorr LLP, Boston, Massachusetts, USA)
Thomas W. White (Partner with Wilmer Cutler Pickering Hale and Dorr LLP, Washington, District of Columbia, USA)
Jonathan D. Rosenfeld (Partner with Wilmer Cutler Pickering Hale and Dorr LLP, Boston, Massachusetts, USA)
Michael R. Dube (Counsel with Wilmer Cutler Pickering Hale and Dorr LLP, Boston, Massachusetts, USA)
Arian M. June (Senior Associate with Wilmer Cutler Pickering Hale and Dorr LLP, Washington, District of Columbia, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 6 April 2012

163

Abstract

Purpose

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The purpose of this paper is to recommend proactive measures that companies should take to manage reports of securities violations under the SEC's new whistleblower program.

Design/methodology/approach

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The paper explains the whistleblower bounty program and recommends ten proactive measures that companies should consider.

Findings

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Companies have an incentive to investigate reports of potential violations quickly while also ensuring compliance with the anti‐retaliation protections.

Practical implications

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Companies should take steps now to bolster internal reporting and investigative procedures and encourage employees to utilize internal reporting mechanisms.

Originality/value

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The paper provides expert advice from experienced securities and financial services lawyers.

Keywords

Citation

McLucas, W.R., Wertheimer, L.S., Robinson, A.J., Jo Johnson, M., White, T.W., Rosenfeld, J.D., Dube, M.R. and June, A.M. (2012), "SEC whistleblower bounties: ten things companies can do right now to stay ahead", Journal of Investment Compliance, Vol. 13 No. 1, pp. 39-40. https://doi.org/10.1108/15285811211216709

Publisher

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Emerald Group Publishing Limited

Copyright © 2012, Emerald Group Publishing Limited

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