Repeated inquiries from clients evidence considerable confusion over the narrow, but important, issue of whether allegations of a violation of the Foreign Corrupt Practices Act (FCPA) by a non-public company can lead to payments of bounties under the recently enacted whistleblower provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Generally, the answer is no.
Read more: No Whistleblower Bounties for FCPA Tips on Private Companies — Jenner & Block
