Sullivan & Cromwell has broad experience in conducting clients' most sensitive and complex corporate and workplace internal investigations. The Firm has recently investigated, reported on and resolved whistleblower claims and retaliation allegations brought against senior executives and corporations in a variety of industries.
S&C's Whistleblower Litigation and Workplace Investigations Group includes eight former federal and state prosecutors; former bank regulatory counsel; and leading practitioners in banking, employment and securities and commodities regulation and enforcement.
The Firm also routinely works with clients to assure measures are in place to address potential legal risks and to establish effective policies and procedures.
The Firm regularly advises clients, including through expedited and thorough internal investigations, on concerns regarding:
  • federal and state false claims act claims;
  • potential violations of federal and state law;
  • information technology and compliance concerns; and
  • employee complaints of co-worker misconduct, including harassment, financial misconduct or other violations of corporate policy.
In addition, the Group advises clients on human resources best practices, including the implementation of policies relating to whistleblowers, employee relations, termination, harassment and conflict resolution.


Sullivan & Cromwell’s recent whistleblower litigation and workplace investigations experience includes representing:
  • A U.S. financial institution, in obtaining a ruling dismissing whistleblower claims brought under the Dodd–Frank Wall Street Reform and Consumer Protection Act, on the ground that the alleged conduct took place outside the United States.
  • A U.S. financial institution, in connection with the accounting and reporting of commercial loans, Sarbanes-Oxley Act whistleblower issues and related SEC investigations.
  • A US financial institution, in connection with investigating whistleblower allegations relating to information technology practices and contracts.
  • An non-U.S. financial services group, in an internal investigation regarding alleged supervisory mismanagement and harassment.
  • A regional bank, in an internal investigation arising from whistleblower allegations.
  • The Audit Committee of a regional bank, in connection with investigating the accounting treatment of certain commercial loans.
  • A leading non-U.S. bank, in internal investigation arising from allegations of kickbacks.
  • A non-U.S. bank, in resolving two whistleblower allegations in varying countries arising from employee allegations of misappropriation of information and trading practices.
  • A U.S. financial institution, in an internal investigation arising from allegations of harassment.
  • A multinational insurance holding company, in internal investigation arising from alleged personal misconduct by executives.
  • A consulting services company, in its internal investigation of allegations of improper conduct by a senior executive of the company. S&C reported results to the board and advised the company on the employment decisions stemming from the report.
  • A consumer goods company, in an internal investigation arising from concerns of corruption.
  • A U.S. manufacturer, in connection with investigating certain revenue recognition practices. 
  • A technology company, in an internal investigation arising from concerns of corruption, finding that no reporting was required.
  • A technology company, in resolving whistleblower allegations, confirming a lack of foundation to the individual’s claims.
  • A software company, in an internal investigation of accounting fraud and obstruction of justice by senior executives.
  • A biotechnology company, in connection with whistleblower litigation relating to a division that the parent company acquired.
  • A technology company, with respect to the termination of an employee who made an ethics and whistleblower complaint.
  • An energy company, in connection with retaliation assertions by a compliance executive.
  • A metal mining company, in an internal investigation arising from a whistleblower complaint.
  • Thomas Weisel, against a qui tam whistleblower suit  brought on behalf of the United States government against Lance Armstrong, the Postal Service bike racing team, and several other individuals associated with the team, including Mr. Weisel, the team’s principal owner.
  • A founder and former CEO of a the largest nonbank mortgage servicer, in connection with defending a qui tam action involving the nonbank mortgage servicer that he built.