New SEC Whistleblowing Rules: Impact on FCPA Compliance

Enhancing Internal Reporting Procedures and Meeting New Investigation and Disclosure Challenges

New rules effective August 12

Recording of a 90-minute CLE webinar with Q&A

Conducted on Thursday, August 4, 2011

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will provide counsel for companies doing business outside the U.S. with guidance on the new SEC whistleblower rules and the impact of the rules on FCPA investigations and disclosures. The panel will offer best practices for FCPA compliance policies and procedures in light of the new rules.


On May 25, 2011, the SEC adopted final rules to implement the whistleblower provisions of the Dodd-Frank Act. These rules are likely to have a significant impact on FCPA enforcement by the SEC and the U.S. Department of Justice.

The SEC rules encourage whistleblowers by paying a bounty of 10-30% of the monetary sanctions. Whistleblowers can report suspicions of bribery and other FCPA violations directly to the SEC, which can both significantly increase FCPA investigations and circumvent internal FCPA compliance.

Companies must promptly address any inklings of FCPA risks or violations. Further, counsel must assess clients' internal reporting policies and procedures—and ensure that policies prohibit retaliation against actual or perceived whistleblowers.

Listen as our authoritative panel examines the new SEC whistleblower rules and the implications for companies doing business outside the U.S., discusses the impact of the rules on FCPA investigations and disclosures, and offers best practices in light of the new rules.



  1. SEC whistleblower rules
    1. Eligibility
    2. Factors in determining whistleblower award
    3. Anti-retaliation provisions
  2. Implementing a compliance program in light of the new rules
  3. Rules impact on FCPA investigations and disclosure
  4. Best practices
    1. Internal reporting procedures
    2. Procedures for investigating whistleblower reports
    3. Internal compliance controls and procedures
    4. Communication with employees and third-party vendors


The panel will review these and other key questions:

  • What are the practical implications of the new whistleblower rules for companies doing business outside the U.S.?
  • What steps can companies take to avoid potential risks of whistleblower reporting?
  • What can companies doing business outside the U.S. do to encourage internal reporting?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Edward J. Fishman
Edward J. Fishman

K&L Gates

Mr. Fishman advises clients with respect to government and internal corporate investigations, corporate transactions,...  |  Read More

Matt T. Morley
Matt T. Morley

K&L Gates

He assists clients in responding to investigations by law enforcement authorities and regulatory agencies, and counsels...  |  Read More

Amy L. Sommers
Amy L. Sommers

K&L Gates

Ms. Sommers focuses on advising on investment and operation in restricted sectors. She is a leading China-based...  |  Read More

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Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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