On July 30, 2016, the United States celebrated its National Whistleblower Appreciation Day. This annual reminder to employees and the public at large of their legal rights to “blow the whistle” is also a reminder to the financial industry of the steadily increasing awards made by the SEC under the whistleblower provisions of the Dodd-Frank Act. This Legal Update serves as an overview of the main points of the Dodd-Frank whistleblower requirements, including some consideration of relevant cases, and suggests that by reviewing the trajectory of awards under the Federal False Claims Act, the financial industry should plan for the likely continued increase of such actions and awards.
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