Regulatory: Corporate Compliance Programs Need Reevaluation

Gardner DavisCorporate compliance programs need to be reevaluated in light of the whistleblower provisions of the recently enacted Dodd-Frank financial reform bill and its powerful incentives for employees to bypass internal systems and report potential problems directly to the Securities and Exchange Commission.

Dodd-Frank mandates that the SEC offer rewards or "bounties" to whistleblowers who provide information about securities fraud and securities law violations (including violations of the Foreign Corrupt Practices Act). The SEC is expected to adopt final rules implementing the provision in April, 2011.

Gardner Davis

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