December 04, 2014

In this article, Jenner & Block Partner Christian R. Bartholomew and Associate J. Douglas Wilson explore the U.S. Securities and Exchange Commission’s whistleblower bounty program.  The authors explain that the SEC in September awarded a tipster a record $30 million.  They then examine the following 10 issues regarding the program: 1. it’s easy to be a whistleblower; 2. the SEC has lots of money; 3. the SEC receives thousands of tips; 4. whistleblowers are not required to first report internally; 5. the SEC rules incentivize internal reporting; 6. the grace period is really a deadline; 7. compliance and audit personnel can be whistleblowers; 8. the rules contain broad anti-retaliation provisions; 9. the SEC is looking for a “message case” and 10. the program is helping the SEC’s enforcement (but how much?).  The authors wrote the article with Paralegal Casey E. Yi.