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Saturday, April 11, 2026

Whistleblower Newsletter Q2 2022 | Foley & Lardner LLP - JDSupra - JD Supra

Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include:

  • Brink’s Company Charged for Unlawful Restriction on Whistleblower Protection
  • D.C. Circuit Court of Appeals Affirms SEC’s Denial of Award to Early Whistleblower
  • Relatively Slow Quarter for SEC Whistleblower Awards Still Results in Awards of Nearly $10 Million

Brink’s Company Charged for Unlawful Restriction on Whistleblower Protection

On June 22, 2022, the SEC announced a settlement with The Brink’s Company (Brinks) concerning alleged violations of Exchange Act Rule 21F-17. Rule 21F-17 prohibits any person from impeding an individual’s communication with the SEC about a possible securities law violation, including by way of a confidentiality agreement. From 2015 to 2019, Brinks required new employees to sign confidentiality agreements (and certain other agreements) that prohibited employees from disclosing the company’s confidential information to third parties without prior authorization and contained no exemption for would-be whistleblowers.

The SEC’s order notes that in April 2015, the SEC brought its first enforcement action for violation of Rule 21F-17 based on a company’s use of a restrictive confidentiality agreement. Thereafter, Brinks’ legal departments received law firm client bulletins, alerts, and other notices regarding this and other, similar...



Read Full Story: https://www.jdsupra.com/legalnews/whistleblower-newsletter-q2-2022-3794431/