Compliance Bricks and Mortar for March 10

These are some of the compliance-related stories that recently caught my attention.

SEC Reduces Whistleblower Bounty Based On Culpability And Delayed Reporting by Harris Mufson, Steven J. Pearlman and Amy Blackwood in Proskauer Whistleblower Defense

On February 28, 2017, in an Order almost entirely devoid of detail, the SEC announced that a whistleblower will receive 20% of any monetary sanctions collected in an enforcement action commenced as a result of the whistleblower’s tip. The SEC is giving this “reduced” award while acknowledging that the whistleblower (1) was “culpable” in the securities violation at issue, and (2) unreasonably delayed reporting the company’s wrongdoing to the agency. [More…]

Beware of “Virus-Infected” Emails Purportedly From the SEC!!! in

Whoa! Last week, a member received an email claiming to be from EDGAR/SEC that had an attachment for revised 10-K filing instructions. She forwarded the email to her IT department – & it turned out the attachment was a “very nasty piece of malware” that could have infected the entire company. It was a phished email that came from a SEC email address ( with a subject line of “Important changes to Form 10-K and Instructions.”

So beware! This is quite a tailored type of malicious email for an in-house lawyer to be receiving! Yesterday, the SEC posted a notice about this phishing scam.

You get what you ask for by Jack Vinson in Knowledge Jolt with Jack

This topic is familiar in many management circles: If you look for something, you will likely find it. If people know you are monitoring or looking for something, they will make an effort to supply that thing. And on the other side, if you don’t ask for that thing / report / result, you won’t get it. [More…]

SEC Enforcement Arm Braces for Cutbacks

The SEC’s enforcement arm is bracing for budget cutbacks that may result in fewer enforcement cases, Bloomberg writes.

Already, the department has halted non-essential travel and the hiring of outside contractors who help in-house lawyers with cases, sources tell the publication. [More…]

Terrorism Financing Via Bitcoin May be Exaggerated by MARA LEMOS STEIN

Law enforcement and regulators best take a measured approach in tackling the potential increase in the use of virtual currencies to finance terrorist activities, as there is still scant evidence the nascent technology will become a preferred method of cash transfer and other means of funding remain readily available and hard to track, said a U.K. intelligence think-tank. [More…]