Covington & Burling

International Top 30 position: 25

SEC doles out minimal benefit to cooperator

Since the enactment of Dodd-Frank, there has been a great deal of focus on rewards for ‘whistleblowing’ — bringing to the government’s attention evidence of wrongdoing that it did not previously know about. Yet a much more common question is how much credit to give wrongdoers who are first approached by investigators, but who could still help them make a fast, easy case against others, if the government made it worth their while. In a recent insider trading action, SEC v Wrangell, the SEC announced that it had rewarded this type of cooperator, but the amount of the reward appears inadequate to induce widespread cooperation.

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265 Strand
London
WC2R 1BH
UK

Firmwide revenue 2011 ($m): 611
Global lawyers 2011: 781