New Weapon in Combating FCPA Violations

Over at Tom Fox’s FCPA Compliance and Ethics Blog, I recently authored a guest post examining the new – and revolutionary – Securities and Exchange Commission’s (SEC) Whistleblower Program, enacted under Dodd-Frank, and its impact on Foreign Corrupt Practices Act (FCPA) enforcement. As I point out in that piece, a qualified whistleblower can receive a monetary award of 10-30% of the monetary sanctions collected in a successful SEC enforcement action. Even better, if a parallel proceeding is brought by another regulatory or law enforcement body for the same FCPA violation, the whistleblower could receive 10-30% of any sanctions in that proceeding as well. This is significant because FCPA violations are often the subject of parallel civil and criminal proceedings. Also, sanctions in this area are often large and headline-grabbing. Moreover, with the program’s strong anti-retaliation provisions, employee whistleblowers can come forward safely and without fear of retaliation. All of this adds up to a potent new tool for law enforcement in combating the bribery of foreign officials. Companies doing business internationally, potential whistleblowers, and professionals with FCPA practices must all be on notice.

Named one of the top whistleblower practices/attorneys in the country by The New York Times, Wall Street Journal, NPR and The New Yorker
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