On August 14, a panel of the Second Circuit held that the Dodd-Frank Act’s whistleblower anti-retaliation provision does not apply extraterritorially.  The panel affirmed the dismissal of a complaint filed by Liu Meng-Lin, a Taiwanese national employed by Siemens China, who claimed that he was retaliated against for reporting internally that Siemens employees were indirectly making improper payments to officials in North Korea and China in connection with the sale of medical equipment in those countries.  In light of its holding that the anti-retaliation provision does not apply extraterritorially, the court declined to reach the issue of whether Dodd-Frank’s whistleblower protections apply to complaints made internally, as opposed to those made directly to the SEC.  Liu v. Siemens AG, 13-4385-cv (2d Cir.) Second Circuit Decision