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).