Don’t Tip Off the Crooks

Don't Tip Off the Crooks


The choice to report a concern internally before going to the government is yours and yours alone. No code of conduct, handbook, or employment agreement can negate this right. looking to encourage company self-reporting, the SEC and CFTC have implemented rules that allow a whistleblower to still qualify for an award if their internal report leads a company to contact the agency about their own misconduct. A grace period exists between the internal disclosure and deadline to go to the government. The IRS and False Claims Act programs are less Keen on internal disclosures and would rather whistleblowers contact them first.

Practice Tips

  • The SEC 120-day rule for providing information to a compliance officer before contacting the SEC is set forth at 17 C.F.R. § 240.21F-4(b)(7).
  • The Commodity Futures Trading Commission’s 180-day rule for providing information to a compliance officer before contacting the CFTC is set forth at 17 C.F.R. § 165.2(i)(3).
  • Best practice: If you report a fraud internally, file your reward claim within 120 days of the initial report to the SEC or 180 days of the report to the CFTC.
  • The whistleblower obstruction of justice law is found at 18 U.S.C. § 1513(e).


  • Rule 10 discusses the problem with corporate hotlines, and
  • Rule 5, Trap 5 (discussing problems triggered by internal reporting)

Frequently Asked Questions

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All purchases or donations proceeds go to support the National Whistleblower Center, a 501(c)(3) non-profit organization dedicated to supporting whistleblowers.

What's Inside

This books covers all federal and state laws regarding whistleblowing, including protections, rewards, and procedures for whistleblowing.

Meet the Author

Stephen M. Kohn is considered the world’s leading authority on international whistleblower law, and behind some of todays modern whistleblower rules.

Introduction: The Revolutionary Roots of Modern Whistleblowing

Law Library

The Law Library is a free companion to the Rules for Whistleblowers, complete with relevant whistleblower cases and important links and resources.

Speaking Engagement

Stephen Kohn enjoys speaking to universities of all sizes, students and professionals, the media, general public, and government officials.

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