As the former Chief of the Office of the Whistleblower at the Securities and Exchange Commission, Jane Norberg brings her extensive experience to help clients navigate regulatory, enforcement, governance, and compliance issues associated with whistleblowers. As a former Special Officer in the Division of Enforcement at the SEC and a former Special Agent with the United States Secret Service, Ms. Norberg also brings her unique background and insights to assist clients in bringing regulatory and governmental inquiries to a successful resolution.
Ms. Norberg represents public and private companies, financial institutions, individuals, and investment advisors on sensitive whistleblower and other complex matters, including internal and government investigations; response to and defense of specific whistleblower allegations; securities enforcement and white collar defense; whistleblower retaliation claims defense; proactive assessment and structuring of internal compliance mechanisms, policies and procedures; training boards of directors, management and workforces on internal reporting and retaliation; and crisis management counseling to mitigate reputational risk. Ms. Norberg also conducts sexual harassment and other sensitive investigations, and educates boards of directors and executives about emerging whistleblower programs such as the Anti-Money Laundering Act whistleblower program and NHTSA automotive whistleblower program.
During Ms. Norberg’s tenure at the SEC—she joined the SEC in 2012 as Deputy Chief of the Office and was appointed to Chief in 2016—she helped develop and lead the SEC’s whistleblower program since near its inception. Under her leadership, the Office’s staff expanded and achieved a record-breaking growth in both the number of whistleblower tips received and awards issued to whistleblowers under the program.
Ms. Norberg has extensive experience and knowledge regarding whistleblower retaliation and is the leading expert on agreements that impede reporting in violation of Exchange Act Rule 21F-17, having directly advised on all whistleblower protection cases brought by the SEC during her tenure. She advised senior SEC leadership on emerging whistleblower issues and policies, as well as reported to Congress regarding the program’s activities. Ms. Norberg also had a substantial advisory role related to the amendments to the SEC’s whistleblower rules and has advised other domestic and international regulators related to the development of new whistleblower programs. While at the SEC, Ms. Norberg also co-led a diversity and inclusion initiative across the Division of Enforcement.
Ms. Norberg is a thought leader and sought-after speaker with respect to whistleblower-related issues and also writes regularly on the topic.
Prior to joining the SEC, Ms. Norberg was in private practice, where she focused on executive compensation and employee benefits. She also previously served as a Special Agent in the United States Secret Service and as a legal intern to Judge Joseph M. McLaughlin, United States Court of Appeals for the Second Circuit.
- Advising a director of a bank related to a dispute over possible securities laws violations and related board obligations.
- A multi-national life sciences company in conducting an internal investigation related to potential accounting violations.
- Training the Board of Directors, management, and employees of a financial institution on an updated whistleblower policy, internal reporting structure, and retaliation policies to encourage and bolster internal reporting.
- Conducting an internal investigation for an international technology company based on an internal whistleblower complaint regarding possible securities laws violations and retaliation allegations. Successfully negotiated the whistleblower’s exit from the company with a full release of claims.
- Conducting an internal investigation into sexual harassment allegations from a whistleblower and providing crisis management advice.
- Developing and revising whistleblower policies, procedures, and reporting structures for a financial institution and its Audit Committee to best capture internal whistleblower reports.
- Advising clients related to language in agreements that may be viewed as impeding reporting to governmental authorities in violation of the securities laws.
- J.D., St. John's University School of Law, with honors
- B.A., Bloomsburg University of Pennsylvania
- District of Columbia
- New York
- Chief, Office of the Whistleblower, Division of Enforcement, Securities and Exchange Commission
- Deputy Chief, Office of the Whistleblower, Division of Enforcement, Securities and Exchange Commission
- Special Agent, United States Secret Service