In a series of press releases throughout September 2023, the Securities and Exchange Commission (SEC) announced enforcement orders against three separate companies for using employment agreements and separation agreements that violated the SEC’s whistleblower protection rule. The orders reflect the SEC’s increased scrutiny of employment agreements and separation agreements under the whistleblower protection rule.

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This post was also written by Amy Greer and Carl Krasik.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) was enacted July 21, 2010. Among other things, it added new Section 21F to the Securities Exchange Act of 1934 (“Exchange Act”). This Section establishes a whistleblower program that directs the SEC (the “Agency”)

As stated in our previous blog posting, President Barack Obama signed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank” or the “Act”) into law on July 21, 2010, with the objective of ushering in a new era of financial regulation and transparency. The Act’s range encompasses not only the usual group of