Philip M. Berkowitz
2019 has been a year of increased regulatory scrutiny of banks’ and other financial institutions’ whistleblower investigation protocols and codes of conduct. Two recent enforcement actions present extraordinary cautionary tales. As Philip M. Berkowitz discusses in his Employment Issues column, each of these matters involved individuals with high level compliance responsibilities, who apparently made very bad decisions, which resulted in enormous monetary and reputational damage to their employers as well as themselves.
November 13, 2019 at 12:50 PM
1 minute read
“An honest man’s pillow is his peace of mind.” John Mellencamp, “Minutes to Memories” (1985).
2019 has been a year of increased regulatory scrutiny of banks’ and other financial institutions’ whistleblower investigation protocols and codes of conduct. In January 2019, for example, the New York Department of Financial Services (DFS) identified 10 pillars for an effective whistleblower program in a newly released Guidance on Whistleblowing Programs.
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