The Dodd-Frank Act: Whistle-blower Rewards in FCPA Cases

On July 21, 2010, President Obama signed the Dodd- Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act") into law. The Dodd-Frank Act primarily introduces major changes in the regulation of the financial services industry, but it also permits whistleblowers in Foreign Corrupt Practices Act ("FCPA") and securities fraud cases to claim a 10% to 30% reward in enforcement actions where the penalties recovered exceed U.S.$1 million. Because penalties in several recent FCPA cases have been in the hundreds of millions of dollars, these provisions of the Dodd-Frank Act could have an important effect on FCPA enforcement.

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