Dodd-Frank’s whistleblower provisions are not limited to employees of the company in question, but can be any individual who provides information relating to a violation of the securities laws to the Commission. This appears to open the door to the next generation of operations like Mark Cuban’s ShareSleuth, which employed an investigative journalist to look for public companies that appeared to be engaging in financial fraud. Full details are available in this post on my Enforcement Action blog over at Compliance Week.
