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Stan Twardy and Doreen Klein offer their view on key aspects of the Dodd-Frank Wall Street Reform and Consumer Protection Act in an article published in the ABA's Criminal Litigation newsletter. "The Dodd-Frank Whistleblower Program: Mutiny over the Bounty" looks at the new bounty program and broad liability clawback provisions established by the Act, which was signed into law by President Obama in July 2010. Stan and Doreen note that these provisions work at cross purposes with companies' efforts to ensure effective internal compliance programs. In the current environment of aggressive enforcement of the Foreign Corrupt Practices Act resulting in increasingly larger penalties, the challenges facing companies now include encouraging employees to use available internal compliance programs in lieu of, or prior to, reporting complaints to the SEC.
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