Whatever your initial view on how the whistleblower provisions may impact FCPA enforcement, it was previously noted that the best part of the whistleblower provisions were that its impact on FCPA enforcement could be monitored and analyzed because the SEC is required to submit annual reports to Congress.
Recently, the SEC released (here) its annual report for FY2016 and, like the prior five years, FCPA “tips” continue to be a minor component of the SEC’s whistleblower program.
Specifically, according to the SEC’s report, of the 4,218 whistleblower tips received by the SEC in FY2016, 5.6% (238) related to the FCPA.
‘Enforcement 40’ for 2020
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