FCPA whistleblower rewards are available to people who would like to remain anonymous. Under the SEC’s reward program, which was established under the Dodd-Frank Act, FCPA whistleblowers can submit their cases anonymously, via counsel, to the SEC.
As background, FCPA whistleblowers are eligible for large rewards for reporting corporate bribery under the Dodd-Frank reward program. An anonymous submission provides the ultimate confidentiality because the SEC does not even know the identity of the whistleblower. A whistleblower is not required to disclose his or her identity or to submit a reward claim if he or she does not want to do so. Sometimes whistleblowers will want anonymity for their initial submissions but decide later to reveal their identities to the SEC in cases where they want to provide further assistance to the investigation or file a reward claim.
In order for a whistleblower to file a submission anonymously under the SEC’s reward program, Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act — (21F.(d)(2)(A) “Required Representation”) — and SEC regulation 21F-9(c) provide that the whistleblower must provide his or her information through an attorney. The SEC has strict protocols in place in order to keep whistleblowers’ information confidential, but some clients still feel more comfortable providing their information to the SEC without disclosing their names.
If anyone has information about an SEC-regulated company (or one of its local partners, subsidiaries, affiliates, or agents) bribing government officials and would like to discuss making a confidential or anonymous submission under the Dodd-Frank reward program, he or she should feel free to contact me for a free confidential consultation.
