In 2016, Swiss pharmaceutical company Novartis coughed up $25 million to resolve a SEC FCPA enforcement action focused on the conduct of its indirect Chinese subsidiaries. (See here).
In the aftermath of the enforcement action, twelve individuals filed applications with the SEC for a whistleblower bounty pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act and the SEC determined that two claimants deserved a joint award.
Two of the ten claimants whose applications were denied, appealed the SEC’s denial to the D.C. Circuit Court of Appeals and in this recent decision the Court sided with the SEC in its denial.