FCPA Whistleblower Bounty?
The SEC recently announced “an award of over $5 million to joint whistleblowers whose tip caused the opening of an investigation that resulted in a successful enforcement action.” According to the SEC, “the whistleblowers provided significant information about misconduct abroad that directly supported certain allegations in the enforcement action.”
The accompanying order is heavily redacted, but does mention that the underlying enforcement action “involved misconduct abroad” and was resolved through an administrative proceeding.
My guess is that the underlying action was likely an FCPA enforcement action. If true, this would be rare instance of a bounty being paid out in connection with an FCPA enforcement action.