Activision Blizzard Inc., a California-based video game development and publishing company, has agreed to pay $35 million to settle charges that it failed to maintain disclosure controls and procedures to ensure that the company could assess whether its disclosures pertaining to its workforce, specifically allegations of misconduct, were adequate. As part of the resolution, Activision Blizzard also settled charges that it violated an SEC whistleblower protection rule. Notable aspects of the settlement include a rarely seen dissenting opinion by SEC Commissioner Hester Peirce that takes exception to the SEC’s standing in this case and the underlying arguments of harm to investors, and the SEC's use of fairly broad risk statements found in Activision’s regular business filings related to attracting and retaining talent as evidence of a known problem with the company’s culture. The Anti-Corruption Report spoke with Ropes & Gray partner Jeremiah Williams and senior advisor Hui Chen about the resolution and what it signals for compliance practitioners. See “ Discussing 2022 Enforcement Results, SEC Enforcement Director Stresses Trust-Building Measures” (Jan. 18, 2023).