Although 2017 has barely begun, the Securities and Exchange Commission (SEC) has continued to aggressively pursue enforcement actions against companies for whistleblower-related violations. As part of its initiative, the SEC...more
Two recent SEC enforcement actions that describe how severance agreements may violate whistleblower protections under the federal securities laws if not properly drafted were the subject of a recent article by Perkins Coie...more
Non-Member Tipper and Tippee Fined by CME Group for Insider-Trading Type Offenses; Two Member Firms Fined for Algo System Gone Wild - Two apparently related non-members of the Chicago Mercantile Exchange agreed to be...more
Following up on our recent coverage of the SEC’s administrative orders in BlueLinx Holdings and Health Net, we now bring you the somewhat dated “news” of interim guidance issued by the Occupational Safety and Health...more
As we discussed, in early August the SEC sued BlueLinx Holdings, Inc. for violations of Rule 21F-17(a) for the way it structured its severance agreements to prevent departing employees from collecting monetary awards if they...more
There have been lots of developments on the whistleblower front over the last couple months, and we’ve covered none of them here at Cady Bar the Door. Let’s try to catch up. Today we’ll discuss the first of this recent...more
The Securities and Exchange Commission (SEC) recently announced settlements with two companies for using severance agreements that allegedly violated Rule 21F-17. [Order Instituting Cease-And-Desist Proceedings, In the Matter...more
On September 15, 2016, the federal Occupational Safety and Health Administration (OSHA) released new policy guidelines for its review of private settlement agreements presented to the agency for approval in whistleblowing...more
On Aug. 15, the U.S. Securities and Exchange Commission issued its second fine in six days to an employer for drafting severance agreements that restricted former employees from collecting awards as whistleblowers. The fines...more
The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments last month to the regulations governing its whistleblower bounty program. A number of the changes are aimed at more closely aligning the CFTC’s...more
In two recently announced settlements, the U.S. Securities and Exchange Commission (SEC) adopted a strict interpretation of the whistleblower protections afforded under the Dodd-Frank Wall Street Reform and Consumer...more
The SEC has fined an Atlanta company $265,000 for using various severance agreements restricting whistleblower activities. The Dodd-Frank Act added ’34 Act § 21F encouraging whistleblower programs. The SEC adopted Rule...more
In less than one week, the Securities and Exchange Commission (“SEC”) announced enforcement actions against two companies that had required their departing employees to waive their rights to any monetary recovery under the...more
On August 15, 2016, the U.S. Securities and Exchange Commission (SEC) issued its second fine in six days to a health insurer for allegedly creating severance agreements that illegally restrict former employees from collecting...more
In April 2015, the SEC announced in a first-of-its-kind enforcement action that certain KBR, Inc. confidentiality agreements violated the whistleblower protections of the Dodd-Frank Act by requiring employees and former...more