Sarbanes-Oxley Act

D.C. Circuit Holds that Whistleblower Provision Does Not Apply Extraterritorially

In Garvey v. Administrative Review Board, the D.C. Circuit held that a whistleblower provision in the Sarbanes-Oxley Act did not apply to alleged retaliation against an employee in Hong Kong by a subsidiary of a U.S. investment bank. The opinion carefully applies the Supreme Court’s two-step framework for the presumption against extraterritoriality to the whistleblower…

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Ingrid (Wuerth) Brunk

Vanderbilt Law School
ingrid.wuerth@vanderbilt.eduEmail

William Dodge

UC Davis School of Law
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Maggie Gardner

Cornell Law School
mgardner@cornell.eduEmail

John F. Coyle

University of North Carolina School of Law
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Zachary D. Clopton

Northwestern Pritzker School of Law
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Noah Buyon

Duke University School of Law
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Will Moon

University of Maryland
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William K. McGoughran

Vanderbilt Law School
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Chimène Keitner

UC Davis School of Law
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Catherine Amirfar

Debevoise & Plimpton LLP
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Justin R. Rassi

Debevoise & Plimpton LLP
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Isabelle Glimcher

Debevoise & Plimpton LLP
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Ben Köhler

Max Planck Institute for Comparative and International Private Law
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Aaron D. Simowitz

Willamette University College of Law
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Timothy D. Lytton

Georgia State University College of Law
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