How To Save Compliance Programs After Dodd-Frank

Law360, New York (April 14, 2011, 12:49 PM EDT) -- Albeit with the best of intentions, the Dodd-Frank Act and the U.S. Securities and Exchange Commission’s proposed implementing regulations threaten to send many corporate compliance programs into the dustbin of disuse. The act gives prospective whistleblowers large financial incentives to report complaints directly to the SEC, bypassing the company entirely.

Although the SEC’s proposed regulations recognize the risks to compliance programs, they do not alter, and in some ways enhance, the whistleblowers’ economic incentives to report problems directly to the government. As a result, companies now...
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