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JPMorgan Responds To Whistleblower Complaint Connected To Its 2016 FCPA Enforcement Action

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As highlighted here and here, in November 2016 JPMorgan (and related entities) resolved a $202.6 million DOJ and SEC Foreign Corrupt Practices Act enforcement action based on its alleged improper hiring and internship practices that the U.S. government has labeled bribery and corruption.

The DOJ action was resolved through a three year non-prosecution agreement involving JPMorgan Securities (Asia Pacific) Limited (“JPMorgan-APAC), a wholly subsidiary of JP Morgan, which involved a variety of requirements and undertakings imposed upon the company – as is typical in resolving FCPA enforcement actions.

As highlighted here, in late 2021 Shaquala Williams (a former employee of JPMorgan in New York city) filed a civil complaint in federal court (S.D.N.Y) against JPMorgan.

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D.C. Circuit Backs SEC’s Denial Of Whistleblower Bounties To Two Claimants In Connection With Novartis FCPA Enforcement Action

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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.

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Thoughts On The JPMorgan Whistleblower Complaint

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This recent post highlighted the whistleblower complaint filed by a former employee of JPMorgan (Shaquala Williams) in connection with the 2016 Foreign Corrupt Practices Act enforcement action against the company.

As described in the prior post, the JPMorgan enforcement action was based on alleged improper hiring and internship practices that the U.S. government labeled bribery and corruption. The DOJ portion was resolved through a three year non-prosecution agreement involving JPMorgan Securities (Asia Pacific) Limited (“JPMorgan-APAC), a wholly subsidiary of JP Morgan, which involved a variety of requirements and undertakings imposed upon the company – as is typical in resolving FCPA enforcement actions.

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FCPA “Tips” Continue To Be A Minor Component Of The SEC’s Whistleblower Program

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The Dodd-Frank Act enacted in July 2010 contained whistleblower provisions applicable to all securities law violations including those under the Foreign Corrupt Practices Act.

In this prior post from July 2010, I predicted that the whistleblower provisions would have a negligible impact on FCPA enforcement. As noted in this prior post, my prediction was an outlier (so it seemed) compared to the flurry of law firm client alerts predicting that the whistleblower provisions would have a significant impact on FCPA enforcement. Many FCPA Inc. participants seemed so eager for a marketing opportunity to sell compliance services, that some even called the generic whistleblower provision the FCPA’s “new” whistleblower provisions.

Whatever your initial view was on how the whistleblower provisions may impact FCPA enforcement, it was previously noted that the best part of the whistleblower provisions was that its impact on FCPA enforcement could be monitored and analyzed because the SEC is required to submit annual reports to Congress.

Recently, the SEC released its annual report for FY2021 and, like the prior ten years, FCPA “tips” continue to be a minor component of the SEC’s whistleblower program.

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Former JPMorgan Employee Files Whistleblower Complaint In Connection With 2016 FCPA Enforcement Action

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As highlighted here and here, in November 2016 JPMorgan (and related entities) resolved a $202.6 million DOJ and SEC Foreign Corrupt Practices Act enforcement action based on its alleged improper hiring and internship practices that the U.S. government has labeled bribery and corruption.

The DOJ action was resolved through a three year non-prosecution agreement involving JPMorgan Securities (Asia Pacific) Limited (“JPMorgan-APAC), a wholly subsidiary of JP Morgan, which involved a variety of requirements and undertakings imposed upon the company – as is typical in resolving FCPA enforcement actions.

Recently, Shaquala Williams (a former employee of JPMorgan in New York city) filed a civil complaint in federal court (S.D.N.Y) against JPMorgan. In summary fashion, the complaint alleges:

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