When Compliance Officers Can Be Whistleblowers

The bounty program under Dodd-Frank rewards whistleblowers who provide information that leads to an SEC enforcement action that totals more then $1 million, but some employees are not eligible to become whistleblowers. Per SEC regulations, they include anyone whose primary duty is compliance or audit, and both in-house and outside personnel conducting corporate investigations. But this post from Littler Mendelson points out there is an important exception to these exceptions. Call it the 120-day rule.