Compliance Officers as Whistleblowers: How Firms Can Adapt
Partner Jeffrey Alberts, head of the White Collar Crime & Investigations practice, and Associate Eric Dowell have authored an article for Compliance Reporter entitled, "C/Os as Whistleblowers: How Firms Can Adapt."
When the Securities and Exchange Commission adopted the final rules for its whistleblower bounty program in 2011, many compliance professionals assumed they were ineligible to receive awards through the program. However, the whistleblower rules include exceptions to the general prohibition on granting whistleblower bounties to compliance professionals – and the SEC has stated that it intends to use these exceptions to incentivize compliance professionals to blow the whistle on their employers.
In light of the SEC’s decision, it is critical for compliance departments to understand how whistleblowing rules work. In addition, compliance departments are well advised to adopt policies and procedures that take these rules into account.
