Bribery rewards are available to international managers. Local country senior managers working for qualifying companies are eligible for large rewards for reporting bribery confidentially to the U.S. Securities and Exchange Commission (SEC). The Dodd-Frank reward program covers corporate violations of the U.S. Foreign Corrupt Practices Act (FCPA). International whistleblowers who provide information about corporate bribery of foreign government officials can receive large rewards. The SEC already has made more than $162 million in payments to whistleblowers. This post will discuss how current or former senior managers working in foreign countries may have reward eligible information relating to bribery. As long as the local senior managers are not considered the “masterminds” behind a particular bribery scheme, they are eligible for a reward. Local senior managers typically know the details of their companies schemes because the funding for the bribes often have to be approved by someone in senior management.
Engaging Suspicious Third Parties at Request of Government Official
Senior management will often be aware of any requests by a government official seeking a bribe. In a case where a large bribe is paid, someone in the local country’s senior management will need to approve the funds for the payment. Oftentimes senior management will be aware if the company is engaging and paying suspicious vendors, suppliers, contractors, consultants, agents, and intermediaries to conduct business with officials because someone in senior management will need to approve the payments. If current or former local senior managers are aware of their companies engaging a suspicious vendor or consultant in connection with winning a contract, bid, tender, or deal (often at the request of a government official), then they should feel free to email me at firstname.lastname@example.org, as this could be very valuable information.
Hiring Relatives of Government Officials
Local country senior managers will often learn about their companies hiring relatives of government officials because someone in senior management will have to approve the hire. If any current or former senior manager is aware of a company hiring a government official’s relative or engaging a business affiliated with a government official, then he or she should feel free to contact me.
Donations and Trips Provided at Request of Government Officials
Senior managers often have to approve “donations” that are made to charitable foundations and entities and will know if a donation was made at the request of a government official. Government officials will often request companies to make payments or “donations” to certain foundations and associations affiliated with themselves. Similarly, government officials will often ask companies to fund or “sponsor” their international and local travel. Any type of company payment – regardless of whether it appears to be going to a charitable entity or to fund travel for a government official – may be considered improper. Anyone with questions regarding the legitimacy of a particular donation or trip should feel free to contact me. For more information and details about how the reward program applies to FCPA whistleblowers, please click here.