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We do believe that the detection of illegal insider trading and establishment of the activity to a legal standard is a monumental task that needs to overcome multiple challenges. Ad-hoc whistleblowing procedures, in addition to routine screening of securities trading are useful, but not enough, in our opinion, if the regulators’ pursuit of illegal insider […]
In an interesting post on his D&O Discourse blog earlier this fall (here), Doug Greene of the Lane Powell law firm raised the question whether there is a securities litigation storm brewing. Citing a number of different factors ranging from the SEC whistleblower program to changes in the plaintiffs’ bar, Greene suggested that we could […]
Companies with effective compliance programs should expect that employees and others will at some point come forward to report potential wrongdoing. After all, internal reporting is one sign their programs are working. If the company determines that there has been a potential violation of the law, it is then faced with a decision that involves […]