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FINANCIAL & CAPITAL MARKETS

Whistleblower program compliance

Whistleblower program compliance in financial and capital markets is under active pressure from multiple directions at once. The U.S. Securities and Exchange Commission has paid out over $1 billion in whistleblower awards under its Rule 21F program, and firms with deficient anti-retaliation policies have drawn enforcement actions, not just guidance letters. The Financial Industry Regulatory Authority and the Consumer Financial Protection Bureau have each added supervisory teeth to internal reporting channel requirements, giving compliance officers three distinct frameworks to reconcile across overlapping product lines.

Watch

  • SEC Rule 21F award volume: trends in award size and covered conduct categories
  • Anti-retaliation enforcement actions targeting confidentiality agreements in employment contracts
  • CFPB supervisory expectations for internal whistleblower intake channels at nonbank lenders
  • FINRA Rule 3110 exam focus on escalation procedures for reportable misconduct
  • Proposed EU Whistleblower Directive implementation gaps affecting U.S. firms with EU operations

Recent material activity in Financial & Capital Markets

Active monitoring in place across Financial & Capital Markets. Material developments related to whistleblower program compliance will appear here as they are published.