Mitigate Potential Whistleblower Violations Amidst Increased SEC Investigations
On April 1, 2015, the Securities and Exchange Commission (SEC) brought its first enforcement action under SEC Rule 21F-17. The rule prohibits companies from taking actions to impede whistleblowers from reporting possible securities law violations to the SEC, including by threatening to enforce a confidentiality agreement. Since then, the Second Circuit's September 10, 2015 decision in Berman has created a circuit split over which whistleblowers are protected from retaliation, which unless and until addressed by the U.S. Supreme creates significant differences in retaliation protections across the country. The SEC's Office of the Whistleblower continues to be very active, as evidenced by recent enforcement statistics.
Given the SEC's increased investigation and awards, broader information requests and more rigid enforcement actions regarding Rule 21F-17 and the conduct of internal investigations into whistleblower allegations, it is crucial for companies and self-regulatory organizations to re-examine their agreements, codes of conduct and other internal documents and strengthen their internal compliance policies to mitigate whistleblower violations.
In a two-hour LIVE Webcast, a panel of thought leaders and professionals assembled by the Knowledge Group will provide the audience with an in-depth analysis of the most important aspects in Mitigating Potential Whistleblower Violations Amidst Increased SEC Investigations.
Key topics include:
- SEC Rule 21F-17 – A Legal Primer, including Discussion of the Current Circuit Split and Issues in Judicial Enforcement and Interpretation
- Identifying and Responding to Whistleblower Violations
- Lists of Violations of Federal Securities Laws
- Risks and Legal Challenges
- Risk Mitigation
- Up-to-the-minute Regulatory Developments
Jane Norberg, Deputy Chief of the Office of the Whistleblower
SEC Office of the Whistleblower
- Opening segment, overview of program
- New stats from new SEC report
- SEC Rule 21F-17
Michael J. Slocum, Attorney
Greenberg Traurig, LLP
- Daniel Berman vs. Neo@ogilvy – likely to go to US Supreme Court
Michael H. Huneke, Attorney
Hughes Hubbard & Reed LLP
- How to respond to a whistleblower report
- Recent report on international nature of this
Who Should Attend:
- FCA Lawyers
- Whistleblower Lawyers
- FCPA and Global Anti-Corruption Lawyers
- Internal and External Compliance Professionals
- White Collar Lawyers
- In-house Counsel
- Civil Litigators
- Other related/interested Professionals and Organizations
Jane A. Norberg joined the SEC in January 2012 as Deputy Chief of the Office of the Whistleblower in the Division of Enforcement. In her capacity as Deputy Chief, Ms. Norberg helps administer the whistleblower program including working with whistleblowers and their counsel, reviewing and analyzing whistleblower applications for awards, and engaging in public outreach to educate potential whistleblowers and other interested parties about the program.
Prior to joining the SEC staff, Ms. Norberg was engaged in private law practice for 14 years, including at Shearman & Sterling LLP.
Jane A. Norberg joined the SEC in January 2012 as Deputy Chief of the Office of the Whistleblower in the …
Michael J. Slocum focuses his practice on labor and employment law, including the defense of discrimination, retaliation, wrongful discharge and whistleblower claims. He has represented employers in a broad array of industries and at the trial and appellate levels in state and federal courts, as well as before a variety of state and federal administrative agencies.
Michael has written and spoken numerous times on a multitude of issues facing employers in diverse industries. He was listed in Super Lawyers magazine as a New Jersey Super Lawyers “Rising Star” in 2013 and was part of the winning team for Law360’s "Employment Practice Group of the Year" and New Jersey Law Journal’s "General Litigation Department of the Year" award in 2013.
Michael received his J.D., with honors, from Rutgers School of Law – Newark and his B.A. from the University of Pennsylvania.
Michael J. Slocum focuses his practice on labor and employment law, including the defense of discrimination, retaliation, wrongful discharge and …
Michael Huneke is a Senior Attorney at Hughes Hubbard & Reed with significant experience conducting anti-corruption investigations and compliance program reviews and representing individuals accused of white-collar offenses. Mike has conducted numerous investigations, including in connection with whistleblower allegations and with U.S. Securities & Exchange Commission, U.S. Department of Justice, U.S. congressional, or World Bank and other multilateral development bank inquiries. Mike has assisted American, Asian, and European clients in designing, implementing, and maintaining anti-corruption policies and compliance programs, including the design and implementation of whistleblowing hotlines. Mike co-authored the treatise Anti-Corruption Law and Compliance: Guide to the FCPA and Beyond, published in July 2014 by Bloomberg/BNA. Prior to joining Hughes Hubbard, Mike clerked on the United States District Court for the Eastern District of Virginia.
Michael Huneke is a Senior Attorney at Hughes Hubbard & Reed with significant experience conducting anti-corruption investigations and compliance program …
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SEC Office of the Whistleblower
About SEC Office of the Whistleblower
About Greenberg Traurig, LLP
Greenberg Traurig, LLP is an international, multi-practice law firm with approximately 1,900 attorneys serving clients from 38 offices in the United States, Latin America, Europe, Asia, and the Middle East. The firm is No. 1 on the 2015 Law360 Most Charitable Firms list, third largest in the U.S. on the 2015 Law360 400, on the 2015 Am Law Global 100, and among the 2015 BTI Brand Elite. More information at: www.gtlaw.com.
About Hughes Hubbard & Reed LLP
Hughes Hubbard & Reed LLP is an international law firm ranked for ten years, including five years in a row as the top-ranked New York-based firm, on The American Lawyer’s A-List of what the magazine calls “the top firms among the nation’s legal elite.” Our attorneys advise and represent clients in over 30 specialized practices from offices in New York, Washington, D.C., Paris, Los Angeles, Miami, Jersey City, Kansas City, and Tokyo. For more information, please visit www.hugheshubbard.com.