Preparing for the Increasing Role of Whistleblowers in FCPA Enforcement

The growth in the Dodd-Frank Whistleblower Program, as revealed in the 2014 Whistleblower Report, has a diverse group of stakeholders – companies, whistleblowers, counsel, the SEC and Congress – clamoring for answers about the scope and application of the Dodd-Frank whistleblower provisions.  In a guest article, David M. Stuart and Omar K. Madhany, partner and associate, respectively, at Cravath, Swaine & Moore LLP, analyze the provisions and how they have been enforced and interpreted.  They also discuss how companies can encourage internal reporting and the importance of ensuring that employee agreements are in compliance with the whistleblower provisions.  See also “Seven Lessons from FCPA Enforcement Trends from FCPA Experts in the Public and Private Sector (Part One of Two)” (Apr. 16, 2014).


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