“An honest man’s pillow is his peace of mind.” John Mellencamp, “Minutes to Memories” (1985).

2019 has been a year of increased regulatory scrutiny of banks’ and other financial institutions’ whistleblower investigation protocols and codes of conduct. In January 2019, for example, the New York Department of Financial Services (DFS) identified 10 pillars for an effective whistleblower program in a newly released Guidance on Whistleblowing Programs.

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