This is part three of my international reward whistleblower series where I address frequently asked questions posed by people who are interested in filing a Dodd-Frank reward submission with the SEC. International and FCPA whistleblowers who report SEC-regulated companies may be eligible for a reward under the Dodd-Frank program. Part I of this series can be viewed here, and part II of the series can be viewed here.
May I Use Company Documents as Evidence to Support My Submission?
Yes, a 2017 case held that SEC whistleblowers can share company documents with the government as long as they are “reasonably necessary to support the allegations of wrongdoing.” Whistleblowers who are planning on submitting company documents and emails to support their case should strongly consider consulting with experienced counsel.
If I Am Involved in the Scheme Can I Still Obtain A Reward?
Yes, as long as the whistleblower is not the mastermind behind the scheme, then he or she is eligible to obtain a reward. Typically, the whistleblowers with the best information are the ones who were involved in the scheme being reported, which is how they obtained much of the information they are reporting. As long as the whistleblower is not the one directing the corrupt conduct in question, he or she should consider reporting the case.
Do I Have to be a Current or Former Employee to Report a Company?
No, almost anyone can file a Dodd-Frank reward submission with the SEC. Current and former corporate employees often file reward submissions based on information they obtained during their employment. However, many reward cases are submitted by people who work for competitors, vendors, and suppliers. In fact, several reward cases have been submitted by employees of corporate channel partners.
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If anyone has information about an SEC-regulated company engaging in corrupt conduct outside of the U.S., please feel free to contact me for a free confidential consultation.