Record-Breaking Year for Whistleblowers Suggests Disconnect in Internal Reporting

In its recently released annual whistleblower report, the U.S. Securities and Exchange Commission reported a record-breaking year under the whistleblower program, with a total of 108 individuals collectively awarded more than $563 million from 86 enforcement actions during fiscal year 2021.

These figures were greater than the total number of whistleblowers who received awards, and the total amount awarded to them, in all prior years since the program’s inception combined. Perhaps most notably, fiscal year 2021 saw a greater percentage of successful insider tipsters that did not report internally prior to bringing concerns to the SEC.

The report highlights the importance of strong internal reporting procedures and mid-level management as an essential frontline for successful compliance programs, topics which are addressed in depth in Cleary Gottlieb’s Global Crisis Management Handbook.

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