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Update: On January 1, 2021, the Senate voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”).
Government Investigations Update
On October 22, 2020, the Securities and Exchange Commission (the “SEC” or “Commission”) announced a $114 million whistleblower award—by far the largest amount ever awarded and more than doubling the previous record of nearly $50 million.[1]
Dodd-Frank created the Securities and Exchange Commission’s (the “SEC” or “Commission”) whistleblower program, which allows the SEC to issue awards to eligible whistleblowers who provide original information that leads to successful enforcement actions with total monetary sanctions above $1 million.[1]
General Counsel and in-house legal departments have long struggled with articulating the risk of and determining the appropriate response to breaches of the company network and the potential exposure of confidential information about employees and third parties. It’s rarely a simple question.
A version of this insight was published in Law360, September 18, 2020
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