Article

Record Breaking Awards and a New FinCEN Whistleblower

Harvard Law School Forum on Corporate Governance

04 Jan 2022

Christine Wong and Logan Wren authored an article for the Harvard Law School Forum on Corporate Governance covering how the recent whistleblower payments from the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) broke new grounds and should serve as a key indicator that companies need to update their internal compliance programs.

“The incentives provided by the whistleblower programs administered by the SEC and CFTC continue to increase as larger and larger payouts become the norm. This past year has seen unprecedented award amounts from both agencies—a clear invitation to any would-be whistleblower. Additionally, both agencies have been willing to overlook negative factors in disclosure while nonetheless issuing massive awards pursuant to their programs… The SEC and CFTC’s recent jaw-dropping awards—and FinCEN’s developing program—are an excellent reminder of why it is so important for companies to have comprehensive and effective internal whistleblowing channels”

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