new whistle-blower program that could lead to huge cash rewards for individuals who provide information about securities law violations to the SEC, including violations of the FCPA.

Under the law, the SEC pays whistle-blowers 10– 30% of any monetary sanctions in excess of $1 million (USD) that the government recovers as a result of the whistle-blower’s assistance. More particularly, a whistle-blower must provide the SEC with “original information” that is “derived from the independent knowledge or analysis of a whistle-blower.”

Some suspect that employees who have heretofore had little interest in FCPA issues may now keep an eye out for potential violations.