Sanctions for Retaliating Against Whistleblower Highlight the Importance of Incentivizing Internal Reporting

What, if anything, can companies do with respect to a whistleblower’s employment without violating the anti-retaliation provisions in the Exchange Act?  In a recent order, the first of its kind, the SEC sanctioned a private fund manager for taking adverse employment actions against a whistleblower who reported principal transaction compliance shortcomings to the SEC.  In light of this decision, what legal or operational options are available to a company that fails to incentivize internal reporting of FCPA and other compliance violations?  See also “Seven Steps Companies Can Take to Incentivize Internal Reporting of FCPA Violations” (Jul. 11, 2012). 

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