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ALI CLE's The Practical Lawyer
With the rollout of the Dodd-Frank whistleblower program, concerns have been raised that the incentives created by Dodd-Frank may tend to undermine, rather than reinforce, the policies and systems put in place because of Sarbanes-Oxley—namely, that the Dodd-Frank program may encourage employees with knowledge of potential wrongdoing to take their concerns directly to the SEC without giving their companies’ internal corporate governance systems a chance to work.
In her article for The Practical Lawyer, the second of a two-part series, Sutherland Partner Amelia Toy Rudolph discusses three areas implicating the balance between internal reporting and external whistleblowing.
Part one discussed the background of the Dodd-Frank whistleblower program, the interplay of the Dodd-Frank whistleblower program and company internal compliance processes, and several topics related to internal whistleblowers and applicability of Dodd-Frank anti-retaliation protection.
Reprinted from the October 2016 issue of ALI CLE’s The Practical Lawyer.