The recent close of the SEC’s fiscal year added notable guidance to a significant period of FCPA enforcement, including several cases that reveal a new feature of the SEC’s efforts to protect whistleblowers. These actions imposed penalties on companies for severance agreements that restricted the ability of employees to seek financial rewards for reporting potential violations of the securities laws to the SEC. They provide further evidence not only of the SEC’s dim view of companies’ efforts to undermine its growing Whistleblower Program, but also of the agency’s desire and ability to use Rule 21F-17 to combat them. In a guest article, Cravath partner David M. Stuart and his associate Kyle S. Gazis explain why these cases are particularly important precedents for companies with worldwide operations. They also analyze the SEC’s latest efforts to defend the Whistleblower Program and the resulting effects on companies seeking to address the risks of FCPA violations. See “Addressing Employees’ Perception That Internally Reporting Compliance Violations Is Futile” (Aug. 10, 2016).