Whistleblowing and the New Race to Report
The impact of the Dodd-Frank Act and 2010's changes to the U.S. Federal Sentencing Guidelines
The Dodd-Frank Wall Street Reform and Consumer Protection Act has created rewards of 10 to 30 percent of monetary sanctions for whistleblowers who report to the Securities and Exchange Commission (SEC) original information leading to securities law enforcement actions that recover more than $1 million.
Press releases announcing settlements by the SEC in the first seven months of 2010 show how large future rewards for whistleblowers could be.
In addition, changes to U.S. Federal Sentencing Guidelines may lead to a reduction in organizational sentences when the organization has an effective compliance and ethics program that incorporates direct reporting obligations from the head of the compliance program to the board of directors or audit committee.
These two developments provide a significant motivation for organizations to drive the effectiveness of their whistleblower system to as high a level as is feasible. This paper explores steps organizations can take to enhance their whistleblower systems and help mitigate their risks.
Learn more by reading Whistleblowing and the New Race to Report: The impact of the Dodd-Frank Act and 2010's changes to U.S. Federal Sentencing Guidelines, available for download above.
Subscribe to receive periodic publications from the Deloitte Forensic Center.