Bribery rewards are now available to international accounting and finance personnel at all levels who report corporate bribery by qualifying companies to the United States Securities and Exchange Commission (SEC). The Dodd-Frank reward program covers corporate violations of the U.S. Foreign Corrupt Practices Act (FCPA). FCPA whistleblowers who provide information about corporate bribery of foreign government officials can receive large rewards. The SEC already has paid more than $150 million to whistleblowers. This post will discuss how current and former accounting and finance personnel – including chief financial officers, chief accounting officers, accounts payable personnel, budgeting and financial controllers, accounting and treasury managers, clerks, and assistants – working in foreign countries may have reward eligible information relating to bribery.
Petty Cash Issues
Accountants and finance personnel often oversee the petty cash custodian and establish the protocols for employees to obtain cash advances. Oftentimes there may be large or frequent cash advances or withdraws by employees that may be suspicious and indicative of bribery or fraud. Reviewing the petty cash log and asking detailed questions of the petty cash custodian may reveal bribery and internal control violations that could be very valuable. If someone has this type of information relating to an SEC-regulated company, he or she should feel free to email me at email@example.com, as this could be valuable information.
Third Party Expenditures: Payments to Suspicious Vendors, Consultants, and Agents
Accountants and financial personnel, including accounts payable managers and controllers, often know if the company has made payments to suspicious vendors or consultants in connection with winning a contract, bid, tender, or deal. Sometimes accountants can see that the company made an irregular or special payment to a consultant, agent, reseller, or distributor to obtain a deal. Oftentimes additional commissions or rebates paid to agents in connection with government deals are indicative of corrupt payments and deals. This type of information can be extremely valuable. If someone has this type of information, he or she should feel free to contact me.
Travel and Entertainment / Employee Expense Reports
Accountants and finance personnel may see unusual or high travel and entertainment expenses being submitted by sales personnel in connection with winning business for the company. This type of information can be indicative of bribery and internal controls issues. If someone has this type of information, he or she should feel free to contact me.
Gifts, Donations, and Sponsorships
Accountants and finance personnel should review closely all expenditures on gifts, donations, and sponsorships, with particular emphasis on all gifts, donations, and sponsorships that were either requested by government officials (or someone on their behalves) or that are in some way going to benefit government officials. If anyone has this type of information, he or she should feel free to contact me. For more information and details about how the reward program applies to FCPA whistleblowers, please click here.