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.
‘Enforcement 40’ for 2020
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