SEC rewards are available to current and former information technology (IT) employees at all levels of qualifying companies who report bribery confidentially under the Dodd-Frank Act. The SEC reward program covers corporate violations of the U.S. Foreign Corrupt Practices Act (FCPA) by SEC-regulated companies. 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 IT employees working for SEC-regulated entities (or local affiliates or subsidiaries of SEC-regulated entities) in foreign countries may have reward eligible information relating to bribery.
Bribery and Corruption Related Emails, Electronic Documents, and Information
Local IT personnel will often come across evidence of bribery and corruption during the course of their work. Current or former IT personnel who come across any emails, documents, or information indicating that their companies (or agents working on behalf of their companies) have provided bribes to government officials should feel free to email me at firstname.lastname@example.org, as this could be very valuable information.
Not Preserving or Destroying Data and Documents During an Investigation
Local IT personnel will often play a role in their companies’ audits, investigations, and compliance reviews. IT personnel who are asked by local senior management to either not preserve or take steps to destroy electronic data and evidence during an investigation or audit may have highly important and valuable information. If current or former IT personnel were asked to do something suspicious or in any way assisted local management to conceal evidence from auditors or investigators, they should feel free to contact me, as this could be reward eligible information.
Retaliating Against or Targeting A Whistleblower
Sometimes local management will attempt to use IT personnel to either uncover the identity of a whistleblower or to target someone who has reported corruption issues. If current or former IT employees have information about their companies targeting whistleblowers or taking any steps to retaliate against them, they should feel free to contact me. For more information and details about how the reward program applies to FCPA whistleblowers, please click here.