---
title: "Compare a whistleblower policy with the Sarbanes-Oxley and Exchange Act provisions"
url: "https://ailawframework.com/practice/in-house-general-counsel/review-the-whistleblower-policy-against-the-act-and-asic-s-guidance/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A40-D20261018-2-US"
practice_area: "In-House / General Counsel"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Compare a whistleblower policy with the Sarbanes-Oxley and Exchange Act provisions

> Set the policy the lawyer supplies beside 18 U.S.C. § 1514A and 15 U.S.C. § 78u-6 and list each place the policy is silent or uses a narrower path than the statute. Do not rewrite the policy that the company adopts.

Canonical page: https://ailawframework.com/practice/in-house-general-counsel/review-the-whistleblower-policy-against-the-act-and-asic-s-guidance/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [In-House / General Counsel](https://ailawframework.com/practice/in-house-general-counsel.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Set the policy the lawyer supplies beside 18 U.S.C. § 1514A and 15 U.S.C. § 78u-6 and list each place the policy is silent or uses a narrower path than the statute. Do not rewrite the policy that the company adopts. |
| What the lawyer must review | 18 U.S.C. § 1514A protects a lawful disclosure, about the securities, mail, wire, or bank fraud and shareholder-fraud conduct the section names, when the employee provides it to a federal regulatory or law-enforcement agency, to Congress, or to a person with supervisory authority or with authority to investigate, discover, or terminate misconduct. The covered employer is a company registered under section 12 of the Securities Exchange Act or required to report under section 15(d), including a subsidiary or affiliate in the consolidated financial statements, a nationally recognized statistical rating organization, and an officer, employee, contractor, subcontractor, or agent of such a company or organization. A complaint may be filed with the Secretary of Labor, and the statute states a 180-day commencement period. 15 U.S.C. § 78u-6 defines a whistleblower by a submission of information relating to a violation of the securities laws to the Commission, in a manner the Commission establishes, and separately prohibits retaliation for providing information to the Commission, assisting a Commission action, or making disclosures required or protected under the Sarbanes-Oxley Act and the other laws named in subsection (h). An award provision applies to a covered action with monetary sanctions exceeding $1,000,000, subject to the rest of the section. A policy that describes only one of these paths is not a statement of both statutes. The lawyer decides what the policy will say. The tool does not decide that a particular disclosure is protected. |
| Written for | United States |
| Applies to | [Review the whistleblower policy against the Act and ASIC’s guidance](https://ailawframework.com/practice/in-house-general-counsel/review-the-whistleblower-policy-against-the-act-and-asic-s-guidance.md) |

## Checking plan

- What the AI does: Set the policy the lawyer supplies beside 18 U.S.C. § 1514A and 15 U.S.C. § 78u-6 and list each place the policy is silent or uses a narrower path than the statute. Do not rewrite the policy that the company adopts.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A report to a supervisor can matter under section 1514A and still not be a submission to the Commission under section 78u-6. The comparison should keep those paths separate.
- State whistleblower statutes and the Securities and Exchange Commission's award rules of procedure were not applied. The lawyer adds them if they govern the employer.

## Sources

- [18 U.S.C. § 1514A (civil action to protect against retaliation in fraud cases)](https://www.law.cornell.edu/uscode/text/18/1514A) (checked 2026-10-22)
- [15 U.S.C. § 78u-6 (securities whistleblower incentives and protection)](https://www.law.cornell.edu/uscode/text/15/78u-6) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*