The Dodd-Frank Whistleblower Provisions: What's Next for Internal Compliance Programs?

On November 3, the SEC issued proposed rules implementing the whistleblower provisions that address some of these concerns. Despite the SEC’s proposed rules, given the large financial incentives at stake for employees, the whistleblower provisions may well have the effect of discouraging the use of internal compliance programs.

Please join Foley for The Dodd-Frank Whistleblower Provisions: What’s Next for Internal Compliance Programs?, during which speakers will:

• Summarize the proposed rules and the concerns expressed by the SEC regarding the tension between encouraging external complaints and supporting internal compliance programs
  
• Discuss some of the difficult questions the SEC has posed for public comment before it finalizes the whistleblower rules
  
• Offer suggestions for developing a “culture of compliance” that would encourage employees to report potential violations of the securities laws internally, notwithstanding the potential incentives to report externally first
  
• Discuss how the proposed rules might intersect with the SEC’s existing enforcement program, specifically the SEC’s prior statements regarding corporate cooperation and corporate penalties

Foley Speakers:

• Bryan House, Partner and member, Securities Enforcement & Litigation and Government Enforcement, Compliance & White Collar Defense Practices


• David Froiland, Partner and member, Labor & Employment Practice and Energy Industry Team