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Abstract: 

Whistleblower programs have changed corporate compliance — and raised the stakes for gatekeepers. With the SEC, CFTC, and DOJ offering strong protections and large monetary awards, whistleblower tips and enforcement have been accelerating. This article explains what that means for corporate counsel, compliance officers, and senior executives, and explores the evolving whistleblower landscape and delivers practical guidance, including how to align internal protocols with regulators’ expectations. Done right, a strong response can turn a potential liability into a compliance advantage.

Keywords: Protocol for Triaging and Escalating Whistleblower Reports; DOJ Corporate Whistleblower Pilot Program

Affiliations:  1: Gibson, Dunn & Crutcher LLP; 2: Gibson, Dunn.