Rule 19: Whistleblowers Beware of Auditors and Compliance Officials

Rule 19: Whistleblowers Beware of Auditors and Compliance Officials

Whistleblowers Beware of Auditors and Compliance Officials


Take Steps to Protect Yourself and Qualify for a Reward


Alert: In February 2018, the Supreme Court of the United States ruled in Digital Realty Trust v. Somers that corporate whistleblowers are not protected under the Dodd-Frank Act if they report only to internal compliance programs. The Court held that a whistleblower must report to the Securities and Exchange Commission to obtain anti-retaliation protections. Although this ruling only concerns the Dodd-Frank Act, its interpretation of this provision could apply to other whistleblower laws that don’t explicitly protect internal whistleblowers. This includes OSHA whistleblower laws, banking whistleblower laws, and most environmental whistleblower laws.

Should I report my concerns internally or to a corporate compliance program? (FAQs)

Statutes and Regulations 

     Compliance Rules under the Federal Acquisition Regulations (FAR)

     Sarbanes-Oxley (SOX) Rules of Professional Responsibility

  • 17 C.F.R. 205 – Standards of Professional Conduct for Attorneys.

Key Cases

Updates and Blogs


Compliance professionals are on the front line of uncovering and reporting fraud. However, the pressure to change audit reports came from the top.

Additional Materials

Whistleblower Attorneys

Stephen M. Kohn – Founding Partner

Michael D. Kohn – Founding Partner

David K. Colapinto – Founding Partner

Mary Jane Wilmoth – Managing Partner

Todd Yoder – Associate Attorney

Kelsey Condon – Associate Attorney

Maraya Best – Associate Attorney

Siri Nelson – Legal Fellow



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