Expatriates at all levels of qualifying companies are now 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 $150 million in payments to whistleblowers. This post will discuss how current or former expatriates working in foreign countries may have reward eligible information relating to corporate bribery.
Sales Department – Knowledge of Bribing Government Decision Makers
Expatriates often manage and assist local corporate sales and marketing teams. During the course of this work, they can become aware of payments and incentives being provided to government decision makers in order to obtain business and deals. Sometimes these payments or trips to officials are made directly by local company personnel, and other times they are made via third party consultants, agents, intermediaries, and channel partners. If current or former expatriates learn of payments to government decisions makers, they should feel free to email me at firstname.lastname@example.org, as this could be very valuable information.
HR and Recruiting Department – Knowledge of Bribing Immigration Officials
Expatriates often become aware of payments being made to immigration officials – either directly by company personnel or indirectly via a third party – to obtain visas, work permits, and residence permits for the company’s expatriates. If current or former expatriates learn of payments to immigration officials, they should feel free to contact me.
Accounting Department – Bribing Regulatory, Customs, and Tax Officials
Expatriates often will manage and assist the accounting and finance departments. In those roles, they often learn about payments or incentives being provided to regulatory officials to obtain licenses, permits, and to avoid various health, safety, and environmental regulations and inspections. They also learn about payments being made to local tax and revenue officials in order to settle a company tax dispute or audit or being made to customs officials via a suspicious customs broker in order to avoid VAT and excise taxes on shipments, avoid customs inspections, or to expedite delivery. If any current or former expatriates become aware of a company paying bribes to government officials, they should feel free to contact me. For more information and details about how the reward program applies to FCPA whistleblowers, please click here.