The Securities and Exchange Commission has a whistleblower program that allows the SEC to provide monetary awards to individuals who provide original information that leads to an SEC enforcement action, including FCPA enforcement actions.  For enforcement actions in which over $1 million in sanctions is imposed, the range for awards for the whistleblower is between 10% and 30% of the money collected in the SEC’s enforcement action.  Certain other restrictions apply, which are described in greater detail here.

The Department of Justice created a similar whistleblower program in August 2024.  It is currently named the Criminal Division Corporate Whistleblower Awards Pilot Program, and applies to certain corporate criminal violations, including violations of the FCPA.  Awards are issued in the DOJ’s sole discretion.  Individuals may be eligible for whistleblower awards if they provide original information that leads to criminal or civil forfeiture exceeding $1 million in connection with a successful prosecution, corporate criminal resolution or civil forfeiture action related to corporate criminal conduct.  Individuals are not eligible for an award under the Pilot Program if they would be eligible under another program.  Certain other restrictions apply, which are described in greater detail here.

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