Earlier today, in a divided 3-2 vote, the SEC adopted final rules to implement the whistleblower provisions of the Dodd-Frank Act. Overall, the final rules appear more permissive and deferential to potential whistleblowers than the proposed rules even though they do provide additional incentives for whistleblowers to utilize corporate compliance systems. As expected, the final rules, like the proposed rules, do not require employees to first report allegations of wrongdoing through a company’s corporate compliance system, despite numerous comments by members of the corporate community urging them to do so.

This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.