When Your Most Trusted Employees Are Working For The SEC

Law360, New York (August 13, 2012, 1:09 PM EDT) -- Could one of your compliance officers, whistleblower hotline or due diligence vendor employees, internal audit employees or even a member of your board of directors be anonymously funneling information about a Foreign Corrupt Practices Act (FCPA) problem at your company to the U.S. Securities and Exchange Commission (SEC) in the hopes of triggering a huge enforcement action and earning a multimillion dollar bounty?

The whistleblower bounty provisions of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act have received a lot of press. As most...
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