A World of Whistleblowers: What Companies Should Know About Dealing With Third Parties Going Forward

The new United States whistleblower program is global in scope and provides incentives to a broad array of individuals. The new rules incentivize a much wider array of individuals than merely corporate insiders to become watchguards of corporate compliance with federal securities laws – including customers, stockholders and academics, market watchers and citizen activists, and third-party service providers. Of these groups, individuals working for third-party service providers are the most likely outside candidates to act on the financial incentives contemplated by the Dodd-Frank Act. They often have access to and work with sensitive corporate information.

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