A retaliation claim brought by a former Morgan Stanley in-house lawyer who was based at a subsidiary in Hong Kong falls outside the scope of a federal corporate fraud law that more broadly protects domestic whistleblowers, a U.S. Labor Department judge said in a new order that embraces earlier decisions limiting the reach of the statute.

The ruling against Christopher Garvey, formerly among Morgan Stanley’s top lawyers in Hong Kong, was the latest decision exploring the contours of anti-retaliation provisions of the Sarbanes-Oxley Act of 2002. Garvey alleged Morgan Stanley leaders forced him out after he raised concerns about alleged foreign bribery and securities regulations. The company has denied the allegations.

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