Executive Investigations

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Fraud Background, Trends & <strong>Executive</strong>s Dodd-Frank Whistleblower Program • Background – July 21, 2010: Dodd-Frank Act signed – May 25, 2011: Final Whistleblower Program approved – August 12, 2011: Whistleblower Program became effective • Rule – An award is given to a whistleblower who voluntarily provides the SEC with "original information that leads to the successful enforcement by the SEC of a federal court or administrative action in which the SEC obtains monetary sanctions totaling more than $1 million." © Grant Thornton 16
"Whistleblower Improvement Act" • Recently introduced House Bill to modify Whistleblower Program • Would require whistleblowers to report violations to employer first – Allows for the following exceptions: o When wrongdoing is conducted by: • compliance officers • highest level of management o When company does not have a robust internal reporting mechanism • Changes payout range from 10-30% to 0-30% © Grant Thornton 17
Page 1 and 2: When Allegations point to the C-Sui
Page 3 and 4: Agenda • Fraud Background, Trends
Page 5 and 6: Fraud Background, Trends & Executiv
Page 15: Fraud Background, Trends & Executiv
Page 19 and 20: Investigation Response & Reporting
Page 27 and 28: Agenda • Fraud Background, Trends
Page 29 and 30: Remediation & Restatements Remediat
Page 31 and 32: Remediation & Restatements Restatem

Executive Investigations

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