Whistleblower Rewards Could Drastically Change FCPA Practice

Corporate Compliance Insights and Complinet
04.01.10

In this article, James Tillen discusses Senate Banking Committee Chairman Christopher Dodd's financial reform bill. Part of Senator Dodd's proposal – which went to the Senate floor March 22 – establishes a new program to reward whistleblowers who assist the SEC in an investigation of securities violations such as violations of the Foreign Corrupt Practices Act (FCPA).

Whistleblowers providing "original information" leading to a successful enforcement action resulting in monetary sanctions exceeding $1,000,000 "shall" be paid between 10 and 30 percent of any money the government collects as a result of the provided information. Whistleblowers will also be paid if their information leads to successful "related actions," i.e., administrative or judicial actions brought by other agencies, including the Department of Justice (DOJ), federal and state regulatory authorities, and foreign law enforcement agencies.

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