FCPA Whistleblower Protection: The Business Facts Behind Your Report

FCPA whistleblower protection is something we address with you alongside the foreign-bribery or accounting concerns you want to report. You may know why a distributor received extra products, why a payment lacked supporting documents, or why a contract changed when it was translated. Our whistleblower experts connect that knowledge to a potential Foreign Corrupt Practices Act case and bring in FCPA whistleblower lawyers suited to your circumstances.

What If My Employer Retaliates?

Talk with our whistleblower experts about your concerns and the report together. We work through those questions with you and FCPA whistleblower lawyers who understand foreign-bribery reporting and employment disputes.

The Securities and Exchange Commission’s protection guidance addresses Dodd-Frank and the Sarbanes-Oxley Act. If your concerns include anonymity, retaliation or an internal report you have already made, those belong in our conversation about your case. We stay beside you through that process.

The Business Behind the Report

A Foreign Corrupt Practices Act concern can involve payments to foreign officials, the company’s accounting records, or the controls over who approves and records a transaction. For the insider, those subjects meet in ordinary business documents: the distributor agreement, the invoice, the payment approval and the record of what the customer received.

A consultant’s invoice describes a service. The deliverable shows what the consultant actually supplied. A reseller’s purchase price and the government customer’s price show where a margin arose. Following the transaction connects the business that signed the contract, the person who approved payment, the bank beneficiary and the accounting entry.

Those roles can sit in different companies and countries. An agent may arrange introductions or handle clearance, while a distributor buys and resells products using a supplier-approved discount. The finance employee who sees the invoice and the sales employee who understands the intermediary’s job bring different parts of that transaction into view.

Bio-Rad’s Distributor Agreements and Extra Products

Bio-Rad’s general counsel reported suspected Foreign Corrupt Practices Act violations in China to the audit committee. The Ninth Circuit’s account describes missing end-user sales records, distributor contracts translated from an older template without FCPA compliance provisions, and reports of extra products in shipments. The concern had a business trail behind it.

According to the opinion, the general counsel and an in-house patent attorney repeatedly tried to obtain the missing sales documents. A senior manager in China told the general counsel that he had never visited a main distributor to look for documents, despite its failure to comply with the company’s requests. The court described another employee’s report this way:

The opinion also recounts the discovery of unauthorized distributor contracts. The Chinese versions came from an earlier template instead of the approved English-language agreements, and junior attorneys reported unauthorized incentives payable in free products. We see a control turned inside out: the approved terms were on paper, but different terms governed the business.

Teva’s Vendor Payments and Internal Controls

At Teva Pharmaceutical USA, an employee working on Latin American finance and internal controls helped prepare memoranda about control deficiencies. The court’s account describes her work monitoring vendor-payment documentation and her participation in government interviews during an FCPA investigation by the Securities and Exchange Commission and the Justice Department. She also alleged that she identified invoices and expense reports indicating potential FCPA violations.

Her work included supporting investigations and helping management implement internal-audit recommendations. The documents she helped prepare addressed improvements to Latin American controls and, she alleged, a continuing failure to correct problems in Argentina. That is the kind of detail a finance employee can bring to a conversation about the business: what the controls called for, what the payment records showed and which concerns had already been raised.

Siemens and Medical-Equipment Sales

A compliance officer in the healthcare division of Siemens China alleged that employees made indirect improper payments to officials in connection with medical-equipment sales in China and North Korea. According to the allegations recounted in the court’s opinion, he raised his concerns through the company’s internal procedures. The reported conduct connected the sale, the payment and the official, the relationships we want to understand when someone brings us a foreign-bribery concern.

Can I Report If I Am Outside the United States?

Yes, the Securities and Exchange Commission accepts whistleblower information from people outside the United States. Its guidance also says that a person need not live or work in the United States to be eligible for an award. We address your questions about overseas work and protection with you and the whistleblower lawyers suited to your circumstances.

What Your Knowledge Adds

The Bio-Rad account connects shipment paperwork and distributor agreements to a specific report to the audit committee. The Teva account shows finance work feeding into internal memoranda and government interviews. In both, employees could describe the business behind the documents.

If you already know which agreement changed, which invoice lacked support or which records the distributor failed to provide, you have a concrete starting point for a conversation with us. We work with you to understand what you saw and how it connects to the people approving, recording and questioning the transactions. You bring the knowledge of the business; we bring experience shaping it into a whistleblower case.

FCPA Whistleblower Awards

The Securities and Exchange Commission’s award program can pay eligible whistleblowers 10% to 30% of collected monetary sanctions in qualifying SEC and related actions. The program requires original information leading to a successful SEC action with sanctions exceeding $1 million. We assess the award opportunity with you alongside your concerns about reporting.

The Justice Department’s Corporate Whistleblower Awards Pilot Program, revised in July 2026, includes foreign corruption and trade, tariff and customs fraud among its covered subjects. We assess any role for that program in your case with the particular transactions and information in view.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. Where your information also concerns fraud against government programs, we look for that case too.

Your Knowledge Can Build a Case

If you know why a foreign payment was approved, what a distributor received or where the accounting trail changed, speak with our whistleblower experts about your report. We connect your knowledge of the business to the award opportunity, bring in FCPA whistleblower lawyers who understand your reporting concerns, and stay beside you as we build your case.