The whistleblower retaliation protections of the Sarbanes-Oxley Act (SOX) do not apply to employees who work overseas for a foreign subsidiary of a U.S.-based corporation, the influential U.S. Court of Appeals for the District of Columbia Circuit ruled recently in a case involving Morgan Stanley. The decision, coming nearly 20 years after the First Circuit ruled the same way in another case, makes it unlikely that another court would now rule to the contrary.

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