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Whistleblower Risk Mitigation & Defense

With federal and state whistleblower incentive programs driving billions of dollars in corporate fines and penalties, the ability to effectively manage an internal whistleblower report from intake through investigation is critical to minimizing operational disruption and reputational risk. Arnold & Porter’s multidisciplinary whistleblower team, which includes former SEC and DOJ officials, SFO prosecutors, and Assistant U.S. Attorneys, handles the full lifecycle of whistleblower matters — we conduct internal investigations, defend against regulatory inquiries, qui tam suits, and retaliation claims, and develop proactive whistleblower policies, training, and risk assessments to help companies get ahead of potential issues.

What sets our team apart is the depth of experience we bring on both sides of the equation — our former regulators understand all too well how agencies build whistleblower cases and what triggers escalation, while our litigators have successfully resolved whistleblower matters for Fortune 500 companies, financial institutions, PE-backed portfolio companies, and publicly listed issuers across industries.

Simply put, we don’t just react to whistleblower complaints; we help clients build the infrastructure to identify and address concerns early — before they become enforcement actions or headline risk.

Experience Highlights

  • JPMorgan Chase in winning two summary judgment motions and a post-trial Rule 50/59 motion in a Sarbanes-Oxley whistleblower action, representing the client from OSHA investigation through jury trial and two related Second Circuit appeals.

  • 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.

  • Publicly listed financial institution in leading an audit committee internal investigation into a whistleblower claim, while also guiding the institution through best practices for managing whistleblower matters at the board level.

  • National audit, tax, and consulting firm in a whistleblower lawsuit by a former employee who alleges her termination for reporting a purported violation was consistent with the company's internal compliance procedures.

  • Multi-billion dollar private equity fund in an internal investigation involving whistleblower, valuation, and financial reporting issues.

  • Multinational healthcare company internal investigation spurred by whistleblower allegations related to potential earnings management practices raising revenue recognition, financial disclosure and internal control considerations.

  • 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.

  • National accounting firm in resolving an internal investigation related to whistleblower allegations of improper conduct in connection with billing practices.

Key Contacts

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Recognition

  • Chambers USA
    Accountant and Auditor Liability (Nationwide) (2025)
    Corporate Crime & Investigations: The Elite (Nationwide) (2015-2025)
  • Best Law Firms Ranked by Best Lawyers
    Financial Services Regulation (National) (2011-2024)
    Financial Services Regulation (Washington, D.C.) (2011-2024)
    Securities Regulation (National) (2011-2024)
  • Chambers Global
    Investigations & Enforcement (International & Cross-Border) (USA) (2021-2026)
    Corporate Crime & Investigations (USA) (2016-2026)
  • BTI Consulting Group
    Gen AI Litigation Leaders (2026)