FCPA Civil Suit Highlights Uncertainties in Dodd-Frank Whistleblower Protections

“The implementing rules for the SEC whistleblower program incentivize whistleblowers to report internally,” Jordan Thomas, a partner at [prior firm] who chairs the firm’s whistleblower representation practice, said. ”However, until a whistleblower reports a possible violation to the SEC in accordance with its procedures — which involves filing a form with the commission — they are not eligible for the employment protections associated with the Dodd-Frank program.” That said, Thomas added that those individuals may qualify for other protections under state and federal laws.