In its recent opinion in Wadler v. Bio-Rad Laboratories, Inc., 916 F.3d 1176 (9th Cir. 2019), the United States Court of Appeals for the Ninth Circuit provided important guidance for determining whether provisions of the Foreign Corrupt Practices Act (FCPA) can be considered “any rule or regulation of the Securities and Exchange Commission,” upon which an employee can base a retaliation claim under §806 of the Sarbanes-Oxley Act (SOX).
