Monthly Archives: June 2013

Extraterritorial Application Of Dodd Frank’s Anti–Retaliation Provision

In Asadi v. G.E. Energy (USA), LLC, Civil Action No. 4:12–345, 2012 WL 2522599, at *7 (S.D. Tex. June 28, 2012), the district court held that “Dodd–Frank’s Anti–Retaliation Provision per se does not apply extraterritorially.” The claimant, a dual United … Continue reading

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Dodd Frank – Implications Of The Final Rules On Internal Reporting Procedures (Part III)

Internal Reporting Alone May Constitute Protected Conduct, If The Report Was Communicated To The SEC By Others, Or The Internal Report Falls Within The “Catch-all” Provision In Egan v. TradingScreen, Inc., NO. 10 CIV. 8202 LBS, 2011 WL 1672066 (S.D.N.Y. … Continue reading

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Dodd Frank – Implications Of The Final Rules On Internal Reporting Procedures (Part II)

Although Not Required, The Final Rules Encourage And Reward Internal Reporting Although the Final Rules do not make internal reporting mandatory, the SEC also plainly states, in several places throughout the regulations, its interest in promoting strong internal compliance and … Continue reading

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Dodd Frank – Implications Of The Final Rules On Internal Reporting Procedures (Part I)

Internal Reporting Is Not Required Internal reporting procedures have been an important part of corporate compliance programs at virtually all regulated companies for many years, and took on an even more prominent role after the enactment of Sarbanes Oxley. With … Continue reading

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Dodd Frank – Procedural Aspects Of The Whistleblower Bounty (Part II)

Calculating An Award Under The “Bounty Program” If an SEC action results in sanctions totaling $1 million or more, the whistleblower is eligible to receive between 10% and 30% of any penalty recovered in a judicial or administrative action. For … Continue reading

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