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SEC Whistleblower Program
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In a groundbreaking case that was first announced in 2015, a Labaton Sucharow whistleblower tipped the Commission to misconduct at two J.P. Morgan wealth management subsidiaries. The Wall Street behemoth agreed to pay $267 million to settle the SEC’s charges, one of the largest enforcement actions initiated by a whistleblower since the program was enacted.
The underlying conduct in the action showcases exactly the kind of corporate greed that Dodd-Frank’s whistleblower program detects, penalizes and ultimately deters. Specifically, the Bank’s subsidiaries failed to disclose a preference to invest client assets in proprietary investment products that enriched the bank, depriving clients of the ability to make fully informed investment decisions.
While wrongdoing of this variety is not uncommon, to stand up and speak out is still the terrain of the most courageous among us. And for that, the whistleblowers should – and in this matter, were – justly rewarded. In 2019, the Commission announced a $50 million bounty paid to a pair of whistleblowers, including an award to our client, a Bank executive, who has elected to remain anonymous.