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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

2014: The Year of the International Whistleblower

The biggest SEC whistleblower award in Fiscal Year 2014 was in September, when the agency authorized a payment of more than $30 million to a whistleblower living outside the United States. The award more than doubled the previous highest award of $14 million.

It was the fourth award to a whistleblower living in a foreign country. The SEC said in September that “allowing foreign nationals to receive awards under the program best effectuates the clear Congressional purpose underlying the award program . . .  to further the effective enforcement of the U.S. securities laws.”

The Dodd-Frank Act amended the Securities Exchange Act of 1934 by directing the SEC to make “awards to eligible individuals who voluntarily provide original information that leads to successful SEC enforcement actions resulting in sanctions over $1,000,000, and successful related actions.” Awards by law are 10% to 30% of the monetary sanctions collected.

In Fiscal Year 2014, the SEC’s whistleblower office received 3,620 tips. Since the start of the award program in August 2011, the SEC has now received a total of 10,193 whistleblower tips, with 3,238 in FY2013, 3,001 in FY2012, and 334 in FY2011.

During FY2014, whistleblower tips came from individuals in 60 foreign countries. The total number of tipsters from outside the United States during FY2014 was 448, or 11.51% of the total number of individuals who filed tips during the year.

The highest number of whistleblower tips in FY2014 from individuals living outside the United States came from the United Kingdom, India, Canada, the People’s Republic of China, and Australia. Here are some numbers:

UK – 70

India – 69

Canada – 58

China – 32

Australia – 29

Argentina – 14

Curacao and Germany – 13 each

Malaysia – 12

Russia – 10

Singapore – 9

Philippines and Poland – 7 each

Thailand, Mexico, and Brazil – 6 each

This map shows in red all countries where whistleblower tips came from during FY2014:

The number of FCPA whistleblower tips in FY2014 was 159, up from 149 in FY2013 and 115 in FY2012.

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The SEC’s 2014 Annual Report to Congress on the Dodd-Frank Whistleblower Program is here (pdf).


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.

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