There is now objective proof that, for whistleblowers seeking substantial bounties for reporting alleged corporate fraud, the False Claims Act is not the only game in town. Indeed, with this week’s announcement by the SEC, it appears that whistleblowers and their counsel can look to the SEC’s whistleblower program, initiated in response to a directive in the Dodd-Frank Wall Street Reform and Consumer Protection Act, see FraudMail Alert No. 10-12-08, as an alternate or additional avenue for recovery in appropriate cases.
Given the significance of this development, we thought that many of our FraudMail Alert readers would be interested in the Firm’s SEC Mail No. 12-08-22 discussing the details of the SEC’s award as well as its implications for corporate compliance programs.