FCPA whistleblower rewards are available to international accounting and finance personnel who report corporate bribery to the United States Securities and Exchange Commission (SEC). FCPA whistleblowers who provide information about companies bribing foreign government officials can receive large rewards.
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. Below are some of the reward-eligible FCPA issues and schemes accounting and finance personnel can report under the Dodd-Frank reward program.
Funneling Payments to Officials Through Third-Party Expenditures
Accountants and financial personnel, including accounts payable managers and controllers, will often discover payments to suspicious suppliers, intermediaries, vendors, agents, and consultants in connection with winning contracts, bids, tenders, and deals. Sometimes accountants will learn about their companies making irregular or “special” payments to consultants, agents, resellers, or distributors 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 these payments are being funneled to government officials.
Petty Cash Issues – Cash Going to Government Officials
FCPA whistleblowers often report cash being given to foreign officials. Accountants and finance personnel typically oversee the petty cash custodian and establish the protocols for employees to obtain cash advances. Oftentimes, there will be frequent cash advances or withdraws by employees that will be suspicious and indicative of bribery and fraud. Accountants and finance personnel who review the petty cash log and ask detailed questions of the petty cash custodian will often uncover bribery and internal control violations that could be very valuable if reported to the SEC under the Dodd-Frank reward program.
Bribing Officials Via Travel and Entertainment & Employee Expense Reports
Accountants and finance personnel may see unusual or large travel and entertainment expenses being submitted by sales personnel via their expense reports 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, this can be very valuable.
Bribing Foreign Officials Through 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). If donations or gifts are being provided to government officials or being provided to foundations or associations that are affiliated with government officials, this can be valuable information if reported under the Dodd-Frank reward program.