Organizations operating internationally are exposed to seemingly endless sources of complainants – employees, former employees, third-party sales agents, suppliers, distributors and even competitors could potentially become whistleblowers. How, in such an environment, does a company decrease the likelihood that it will be the subject of a whistleblower complaint? Corporate whistleblowers remain one of the top concerns of companies subject to the FCPA. That concern is fueled by the recent implementation of the Dodd-Frank Act’s reward program, which awarded its second money prize on June 12, 2013 to whistleblowers who provided information about a “sham” hedge fund and its chief executive. Experts predict that more awards are soon to follow. During two recent panels – one held at the American Bar Association’s Fifth Annual National Institute on Internal Corporate Investigations and Forum for In-house Counsel, and the other at the Practising Law Institute’s Foreign Corrupt Practices Act and International Anti-Corruption Law Developments 2013 program – FCPA practitioners discussed strategies for identifying, preventing and addressing whistleblower allegations. See also “Specific Strategies from Pfizer, Barrick Gold and Other Leading Companies for Handling Actual and Potential FCPA Whistleblowers
,” The FCPA Report, Vol. 1, No. 11 (Nov. 7, 2012).