Seven Steps Companies Can Take to Incentivize Internal Reporting of FCPA Violations

When real or potentially unlawful conduct is occurring at a public company or regulated entity, learning of it in real time and addressing it quickly is critical to that entity’s ability to respond and manage reputational and financial fallout.  The Securities and Exchange Commission’s Whistleblower Rules (promulgated under Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act), which award whistleblowers a percentage of the penalty paid by the company to the SEC as a result of the information from the whistleblower, contain certain key provisions.  In a guest article, Thomas Sporkin, a Partner at BuckleySandler LLP, outlines seven ways in which these provisions can be leveraged by entities to incentivize whistleblowers to report information internally, thereby providing the company with additional time to properly understand, contain, remediate and, in certain instances, self-report potential violations of the federal securities laws, including the FCPA.  See “When and How Should Companies Self-Report FCPA Violations? (Part Two of Two)” (Jun. 20, 2012).

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