Figuring out how well a program is doing is always difficult because the sponsor has every reason to claim success. As the scandal caused by Bernard L. Madoff’s Ponzi scheme shows, it is as much a matter of taking whistle-blowers seriously as it is getting them in the door.
Five years into the program, it is clear that some of the best information comes from corporate insiders. They can give the S.E.C. a map to how a firm operates and where to look for wrongdoing.
‘Enforcement 40’ for 2020
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