Recent SEC Order Reiterates Need for Affirmative Whistleblower Exclusion
Trading Secrets
AUGUST 17, 2022
Since 2015, the SEC has brought at least 14 enforcement actions involving Exchange Rule 21F-17(a). The action arose because, between April 2015 and April 2019, Brinks used an employee confidentiality agreement that prohibited employees from disclosing confidential company information to any third party without Brinks’ prior written approval.
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