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, especially those associated with whistleblowers. As a former Senior Officer in the Division of Enforcement at the SEC and a former Special Agent with the United States Secret Service, Jane also brings her unique background and insights to assist clients in bringing regulatory and governmental inquiries to a successful resolution.
Jane 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 whistleblower allegations; securities enforcement defense; whistleblower retaliation claims defense; and provides crisis management counseling to mitigate reputational risk. She also counsels clients on proactive assessment and structuring of internal compliance mechanisms, policies, and procedures and training boards of directors, management and workforces on internal reporting structures and retaliation. Jane 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. She is a member of the firm's Environmental, Social, and Governance (ESG) working group.
During her tenure at the SEC — she joined the SEC in 2012 as Deputy Chief of the Office and was appointed to Chief in 2016 — Jane 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 the number of whistleblower tips received, including tips related to ESG issues and other emergent areas.
Jane 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. She also advised other domestic and international regulators related to the development of new whistleblower programs.
While at the SEC, Jane co-led a diversity and inclusion initiative across the Division of Enforcement.
Jane is a thought leader and sought-after speaker with respect to whistleblower-related issues and writes regularly on the topic.
Prior to joining the SEC, Jane 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.
- Multi-national life sciences company in conducting an internal investigation related to potential accounting violations and “channel stuffing” reported by a whistleblower.
- Technology company related to an SEC investigation into cybersecurity disclosures.
- Multi-national manufacturing company in conducting an internal investigation into sexual harassment allegations from a whistleblower and providing crisis management advice.
- Tech executive in an SEC subpoena and investigation.
- International technology company in an internal investigation based on a 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.
- Director of a bank related to a board dispute over possible securities laws violations and related board obligations to the bank and its shareholders.
- J.D., St. John's University School of Law, with honors
- B.A., Bloomsburg University of Pennsylvania
- District of Columbia
- New York
Government & Military Service
- 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
Planning Committee, Northwestern Pritzker School of Law Securities Regulation Institute