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Whistleblower Risk Mitigation & Defense

With federal and state whistleblower incentive programs costing companies billions of dollars in fines and fees, successfully navigating an internal whistleblower report and investigation to reduce operational impact and reputational risk is a must. Arnold & Porter brings broad experience and deep understanding of whistleblower issues to effectively handle even the most complicated whistleblower situation, setting up companies for more favorable outcomes. Our multidisciplinary team, including former SEC, DOJ, SFO, Assistant US Attorneys and other prosecutors, advises and assists with handling internal whistleblower reports and internal investigations; defending against governmental and regulatory investigations, qui tam suits and other whistleblower claims; and developing proactive risk assessments, whistleblower policies, training, and best practices regarding internal report intake and triage.

50+ attorneys that were formerly with federal or state agencies/depts. overseeing the financial sector.
Jane Norberg, former SEC Office of the Whistleblower Chief, joins team.

Experience Highlights

  • International technology company regarding an internal investigation into a whistleblower complaint regarding possible securities laws violations and retaliation allegations. We also successfully negotiated the whistleblower’s exit from the company, including a full release of claims.

  • Multinational investment bank in its successful defense and appeal of Sarbanes-Oxley whistleblower case.

  • Multibillion-dollar bank holding company in a comprehensive internal investigation of the organization’s IT systems and controls in response to an internal whistleblower complaint of insufficiency.

  • Special committee of the board of directors of a public automotive company in a large and substantial independent internal investigation into whistleblowers’ allegations of securities, criminal and other laws and regulations violations. The SEC OIG and DOJ also opened separate investigations into the conduct of certain former employees; the SEC enforcement investigation closed without any action taken against the company.

  • Major waste disposal company in California in an attorney general investigation of whistleblower allegations and proposed qui tam lawsuit resulting in no further action by the California Attorney General.

  • A private equity firm in securing favorable rulings of all claims in an arbitration before a retired federal district court judge involving whistleblower claims of a Chief Compliance Officer who was terminated after raising various compliance concerns.

  • Nonprofit social services organization in successfully defending against federal and state False Claims Act whistleblower and retaliation claims concerning alleged improper use and misappropriation of government funds and grants, and in securing a highly favorable settlement following two-day deposition of plaintiff.

  • Audit Committee of a UK-listed company in an internal investigation into protected disclosures made by a whistleblower, who alleged misconduct by one of the company's executives.

  • Special committee of the board of directors of a multinational publicly traded financial services company in an internal investigation involving whistleblower issues and breaches of duty relating to AML and fraud compliance. The investigation follows a series of settlements between the company and government regulators, including the state attorney general, DOJ, and FTC.

Key Contacts

Jane Norberg
Jane Norberg
Washington, D.C.
+1 202.942.5349
Daniel M. Hawke
Daniel M. Hawke
Washington, D.C.
+1 202.942.6743
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  • U.S. News & World Report and Best Lawyers
    "Best Law Firms" for Securities Regulation—Washington, D.C., National (2024)
    “Best Law Firms” for Financial Services Regulation—Washington, D.C., National (2024)
  • Chambers USA
    Corporate Crime & Investigations: The Elite (Nationwide) (2024)
    Securities: Regulation: Enforcement (Nationwide) (2024)
  • FT Innovative Lawyers
    “Standout”—North America (2023)