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Rules Governing the SEC Whistleblower Reward Program

The rules governing the SEC Whistleblower Program are voluminous and somewhat complex.  But to maximize the chance of the SEC acting on a whistleblower tip and qualifying for a SEC whistleblower award, it is important to master these rules.  More than 22,000 whistleblower have submitted information to the SEC Whistleblower Office using Form TCR.

In 2011, one of our attorneys helped shape the rules implementing the Dodd-Frank whistleblower provisions, and led a coalition of whistleblower rights organizations in meetings with the SEC Chair, SEC Commissioners and senior enforcement staff.  We have achieved success for SEC whistleblowers by utilizing the SEC whistleblower rules to maximize future potential awards, and routinely counsel whistleblowers worldwide about whistleblower rewards and protections.

To date, the SEC has received approximately 22,000 whistleblower tips, but fewer than 60 whistleblowers received awards.  It is imperative that whistleblowers prepare high-quality submissions that persuade the SEC to devote limited resources to investigating the whistleblower’s disclosure.

Guide to SEC Whistleblower Rules

We work with whistleblowers worldwide to leverage the SEC whistleblower rules to maximize an award.  Download our free guide to the SEC whistleblower rules SEC Whistleblower Program: Tips from SEC Whistleblower Attorneys to Maximize an SEC Whistleblower Award:

SEC Whistleblower Rules: Know Your Rights and Protections

SEC whistleblowers have important rights and protections, including protections against retaliation under both the Dodd-Frank Act and the Sarbanes-Oxley Act.  Download our free guide to Sarbanes-Oxley Whistleblower Protection: Robust Protection for Corporate Whistleblowers

Why Should You Retain an Experienced SEC Whistleblower Lawyer Familiar with the SEC Whistleblower Rules?

The SEC Whistleblower Program permits anonymous submissions when the whistleblower is represented by counsel.  Click here to learn the answers to these questions about anonymous whistleblower tips:

  • Can I still receive an award if I submit a tip anonymously?
  • How will my attorney submit an anonymous tip on my behalf?
  • How could an anonymous tip potentially expose me as the whistleblower?
  • Are there any disadvantages to anonymous whistleblowing?
  • Will the SEC ever know my identity if I submit a tip anonymously?

In addition to helping protect the identify of a whistleblower, an experienced whistleblower lawyer can increase the chances that the SEC will act on a tip and can advocate on behalf of the whistleblower to try to obtain the maximum award percentage. A whistleblower attorney can also represent the whistleblower in all interactions with the SEC and provide advice on mitigating the risks entailed in whistleblowing.

In addition to preparing a whistleblower submission on Form TCR, an SEC whistleblower attorney can determine the appropriate evidence to provide (or not provide) to the SEC as well as advise the whistleblower on any potential exposure as a result of providing the evidence. Finally, and as a practical matter, the SEC will likely view a whistleblower’s tip as more credible if it is submitted by a reputable SEC whistleblower attorney who has prior experience working with the SEC Whistleblower Office.

Click here to learn more about the benefits of experienced whistleblower representation.

Impact of SEC Whistleblower Rules in Recent Whistleblower Award Determination

A recent November 2017 order determining whistleblower award claims highlights the importance of adhering to and leveraging the SEC whistleblower rules to increase the likelihood of obtaining a SEC whistleblower award.  In that order, two claimants each received an award of approximately $8M, and five claimants were denied any award.

  • The successful whistleblowers provided original information and provided such information voluntarily, i.e., “prior to receiving a request, inquiry, or demand from the Commission.”
  • One of the successful whistleblowers provided significant information that became the focus of the investigation and subsequent enforcement action.  And the whistleblower continued to assist the staff performing the investigation, including the identification of potentially relevant documents and witnesses.
  • Two of the claimants that were denied awards failed to provide original information, i.e., the information that they provided was already known to the SEC.
  • Two claimants failed to show that their submission significantly contributed to the success of an enforcement action.  In other words, they were unable to demonstrate that something unique about their submission made an additional significant contribution to the success of a covered action.  In particular, they provided information that was largely duplicative of other information that staff had already received or had learned during the course of its investigation.

SEC Whistleblower Rules Governing SEC Whistleblower Process

How to Qualify for a SEC Whistleblower Award Under the SEC Whistleblower Rules

SEC Whistleblower Lawyers

Resources About SEC Whistleblower Rules

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Top-Rated SEC Whistleblower Law Firm Representing Whistleblowers Nationwide

Leading SEC whistleblower law firm Zuckerman Law is privileged to represent whistleblowers in claims brought under whistleblower reward and whistleblower protection laws.  Though our clients work in a wide variety of industries and locations, they typically have one thing in common — they choose not to look the other way when they see wrongdoing and instead speak up. 

Our clients deserve an experienced and zealous whistleblower advocate to help them effectively navigate the maze of whistleblower laws and fight hard to obtain the maximum recovery.

To schedule a free, confidential preliminary consultation with our whistleblower attorneys, click here or call us at 202-262-8959.

Whistleblower rewards and whistleblower protection laws are complex and while they can offer substantial rewards, there are many pitfalls that must be considered when devising an effective strategy in a whistleblower case.

We have assembled a team of experienced whistleblower lawyers that enable us to achieve exceptional results for our clients, including multi-million dollar SEC whistleblower awards.  Our team includes a licensed CPA and CFE who worked at a big four audit firm and has experience investigating complex fraud schemes.

We have secured awards for seven whistleblowers, and the courageous whistleblowers that we represent have helped stop more than $1 billion in Ponzi schemes and other fraudulent investment schemes.

In matters in which we obtained SEC whistleblower awards for our clients, the public orders announcing the awards note the “significant assistance” provided to SEC staff that enabled the SEC to complete SEC investigations more quickly.

Recently the Association of Certified Fraud Examiners published a profile of Matt Stock’s success working with whistleblowers to fight fraud:

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In 2022, whistleblower lawyer Jason Zuckerman was named to Washingtonian Magazine’s “Top Lawyers Hall of Fame.”

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Award-Winning Whistleblower Attorneys

U.S. News and Best Lawyers® have named Zuckerman Law a Tier 1 firm in Litigation – Labor and Employment in the Washington DC metropolitan area. In addition, Firm Principal Jason Zuckerman has been:

  • recognized by Washingtonian magazine as a “Top Whistleblower Lawyer” in 2022, 2021, 2020, 2019, 2018, 2017, 2015, 2009, and 2007;
  • rated AV Preeminent® by Martindale-Hubbell based on peer reviews;
  • selected by peers to be included in The Best Lawyers in America® in the category of employment law (2011-2024);
  • rated 10 out of 10 by Avvo, based largely on client reviews; and
  • selected by peers to be listed in SuperLawyers (2012 and 2015-2024) in the category of labor and employment law.

Top-Rated SEC Whistleblower Attorneys

An experienced SEC whistleblower attorney can maximize the likelihood of recovering an SEC whistleblower award. Under the SEC Whistleblower Program, the SEC is authorized to pay awards for original information about any violation of the federal securities laws, including:

See our column in Forbes:  One Billion Reasons Why The SEC Whistleblower-Reward Program Is Effective.

To learn more about incentives for whistleblower to disclose fraud to the SEC, download our free guide SEC Whistleblower Program: Tips from SEC Whistleblower Attorneys to Maximize an SEC Whistleblower Award.

In our guide to the SEC whistleblower program, the whistleblower lawyers at Zuckerman Law share their experience gained from representing whistleblowers before the SEC.

Feedback from Whistleblower Clients

WHEN REVIEWING INFORMATION ABOUT TESTIMONIALS OR STATEMENTS REGARDING A LAWYER’S QUALITY, CONSIDER THAT 1) THE FACTS AND CIRCUMSTANCES OF YOUR CASE MAY DIFFER FROM THE MATTERS IN WHICH RESULTS AND TESTIMONIALS HAVE BEEN PROVIDED; 2) ALL RESULTS OF CASES HANDLED BY JASON ZUCKERMAN ARE NOT PROVIDED AND NOT ALL CLIENTS HAVE GIVEN TESTIMONIALS; AND 3) THE TESTIMONIALS PROVIDED ARE NOT NECESSARILY REPRESENTATIVE OF RESULTS OBTAINED BY JASON ZUCKERMAN OR OF THE EXPERIENCE OF ALL CLIENTS OR OTHERS WITH JASON ZUCKERMAN. EVERY CASE IS DIFFERENT, AND EACH CLIENT’S CASE MUST BE EVALUATED AND HANDLED ON ITS OWN MERITS.

  • Jason Zuckerman is the most focused, thoughtful and aggressive attorneys I have ever known, let alone had the pleasure to have on my side in a highly complex legal case. He brought well-honed legal insights and a rapid pace to our legal preparations. He forcefully brought those preparations to the opposing side, which gave them little choice but to engage with us until a positive settlement was reached. In addition, we found Jason to be extremely responsive at every step, even if it required working past midnight. His character is beyond reproach and his dedication through the entire process was unwavering. If I ever need someone in my legal court again, I won’t hesitate for even a second, before I seek Jason’s support.
  • Jason is everything you could possibly ask for an an attorney: highly intelligent, thoughtful, and extraordinarily knowledgeable in his specialty of the law.  In a very short period of time Jason was able to assimilate a laundry list of details and offer a compelling strategy on how to effectively proceed.  Moreover, he is extremely responsive.
  • Jason is the consummate professional when it comes to SOX retaliation claims. He is, without question, one of the most deeply knowledgeable, technical, and astute attorneys in this very specialized body of law. During one of the most difficult times in my professional career, Jason not only provided exceptional legal guidance, but equally as important, he provided emotional support that was vital to my family and me.

 Jason ran circles around the “major national law firm” team that was assigned to defend my employer. In fact, Jason made them look silly at times. Jason always advocated my best interests, not his own. 

Jason is not only an exceptional attorney who helped my family to achieve a favorable outcome, but he is a friend. I’ve worked with major law firms throughout my career and when it comes to SOX and employment law matters, there is not a finer, more talented attorney than Jason Zuckerman.
  • Jason did an exceptional job in quickly understanding the intricacies of my case, grasping not only his field of expertise of employment law, but also the violations of law and SEC Regulations that were central to my dispute. The overall strategy he utilized insured that opposing counsel was challenged and made clear that this case would simply not proceed based on a timetable convenient to them. Jason is thorough, accurate and seemingly working at all hours based on phone calls and correspondence. Fortunately Jason has a very down to earth personality, understands issues readily and can convey in understandable language current “legal” circumstances and probable outcomes. I would easily and thoroughly recommend Jason for issues related to a Sarbanes-Oxley or employment related dispute.
  • I selected Jason to handle my case after consulting with three other lawyers because of his extensive SOX experience and negotiation skills. My decision paid off as he easily surpassed all of my expectations. He quickly analyzed the merits of my case and aggressively engaged my former employer to reach a favorable settlement, avoiding years of potential litigation. He was responsive, professional, ethical and a great advocate on my behalf. I truly believe that I could not have found a better lawyer to represent my interests. He would be the first person I would recommend if a colleague or friend were to ever need similar services. Put simply, Jason is a top notch lawyer who works tirelessly to achieve a positive outcome for his clients. It’s easy to see why he is regarded as an expert in the field.
  • Thank the Lord I found Jason Zuckerman. I was in a bad situation; I was put on leave from my company after reporting to the Board of Directors that the CEO asked me to make some questionable accounting entries (I was the CFO). The company took the CEO’s side and I was left out in the cold by trying to do the right thing. I was left hanging on leave and being interviewed by a company hired investigator. I found Jason and he immediately put me at ease and took over. All of a sudden the company was on the defensive and I was on the offensive. It was over in two weeks.
  • I hired Mr Zuckerman to pursue an action against a former employer that was attempting to use deceit in its pursuit of federal contracts, and which fired me for not participating in its schemes. Jason was not just very responsive, he was also engaging, spending a good deal of time and effort with me on the phone and by email learning the ins and outs of the case, discussing strategy, laying out alternatives, anticipating counter-arguments, etc, all with the highest integrity. In the end, Jason was able to negotiate a substantial settlement for me, and I believe the company learned not to fire employees for failing to participate in lying to the government. All in all, a very good outcome.I have had the opportunity in my career to interact with numerous attorneys. Jason truly stands out. I wholeheartedly recommend him to anyone seeking a lawyer for wrongful termination and related employment issues.

Tips for Whistleblowers to Qualify for an SEC Whistleblower Award

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Whistleblower Rewards for Reporting Sanctions Evasion

The Anti-Money Laundering Whistleblower Improvement Act of 2022 amended the Anti-Money Laundering Act (AMLA) to require the Department of the Treasury to pay awards to whistleblowers for voluntary disclosures of original information that results in the collection of penalties above $1 million for a violation of U.S. sanctions.

A whistleblower who reports original information about sanctions evasion can obtain an award of 10% to 30% of the collected monetary sanctions.  Sanctions evasion whistleblowers can report anonymously if represented by an attorney.  The AMLA also provides a remedy for whistleblowers that suffer whistleblower retaliation.

Call us today to find out more about whistleblower incentives and protections and how we can help you report sanctions evasion and qualify for a whistleblower award.  You can contact us by phone or via WhatsApp or Signal at 202-930-5901 or 202-262-8959.

See our guide to the OFAC Whistleblower Reward Program: Strengthened Enforcement of Sanctions Evasion Enhances Incentives for Sanctions Whistleblowers and the Whistleblower Lawyer’s Guide to the Anti-Money Laundering Whistleblower Program.

Guidance on OFAC’s Enforcement and Compliance Policies

OFAC Sanctions Evasion Whistleblower Reward Program

Reporting a Violation of U.S. Economic Sanctions Can Qualify for a Whistleblower Award Under AMLA or SEC Whistleblower Reward Programs

sanctions evasions whistleblower attorneysViolating U.S. economic sanctions can implicate violations of disclosure duties under federal securities laws and therefore whistleblowing about sanctions evasion can potentially qualify for an SEC whistleblower award.
For example, Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 requires SEC-registered issuers to disclose all Iran-related activities covered by sanctions restrictions. The SEC’s Office of Global Security Risk (OSGC) monitors issuers’ disclosures related to business activities involving US-sanctioned counties.
And under Section 13(r) of the Exchange Act, issuers required to file Form 10-K, Annual Reports on Form 20-F and Quarterly Reports on Form 10-Q must disclose contracts, transactions and dealings with Iranian entities. Section 219 of the Iran Threat Reduction and Syria Human Rights Act added new Section 13(r) to the Exchange Act.
Recent Office of Foreign Assets Control penalties for sanctions violations have been substantial.  In March 2017, Zhongxing Telecommunications Equipment Corporation paid $100,871,266 in a settlement agreement for 251 apparent violations of the Iranian Transactions and Sanctions Regulations.  ZTE used third-party companies to surreptitiously supply Iran with a substantial volume of U.S.-origin goods, including controlled goods appearing on the Commerce Control List.

OFAC Sanctions Evasion Whistleblower Rewards Law Firm

The sanctions evasion whistleblower lawyers at Zuckerman Law have experience representing sanctions evasion whistleblowers and one of our attorneys is also a Certified Public Accountant and Certified Fraud Examiner.

Experienced and effective sanctions evasion whistleblower attorneys can provide critical guidance and effective advocacy to whistleblowers to increase the likelihood that they get the maximum award from the FinCEN Whistleblower Program.

U.S. News and Best Lawyers® have named Zuckerman Law a Tier 1 firm in Litigation – Labor and Employment in the Washington DC metropolitan area.

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For more information about sanctions evasion whistleblower rewards and bounties, contact the whistleblower lawyers at Zuckerman Law at 202-262-8959.

Click here to read reviews and testimonials from former clients.

OFAC Enforcement Process

A CRS report titled Enforcement of Economic Sanctions: An Overview provides the following summary of OFAC’s enforcement process:

“If OFAC suspects that a person or entity may be acting in violation of economic sanctions, it may open enforcement proceedings. Based on the evidence, OFAC may issue a finding of no violation, a request for further information, a cautionary letter, a finding of a violation, a finding of a violation with civil monetary penalty, or a criminal referral. Should OFAC have reason to believe that the sanctions violation may be ongoing or recur, it may also issue a cease-and-desist order. Where relevant, OFAC may also revoke, suspend, modify, withhold, or deny licenses to engage in certain transactions.

If OFAC imposes a monetary penalty, the amount varies depending on the relevant statutory authority and an
evaluation of the circumstances. To calculate the penalty, OFAC first determines the “base amount” by considering whether the violation qualifies as “egregious” and whether the individual voluntarily self-disclosed the violation. The egregiousness determination is based on a consideration of factors including the violator’s willfulness, harm to the sanctions program’s objectives, and individual characteristics (e.g., commercial sophistication). Then OFAC considers aggravating and mitigating factors, including whether the violator took remedial action or cooperated with OFAC’s investigation to calculate a final penalty. Should OFAC believe that a particular case might warrant criminal penalties, it may refer the case to DOJ. Violators face civil penalties of up to $250,000 (which, as annually adjusted under the Federal Civil Penalties Inflation Adjustment Act of 1990, now amounts to $368,136) or “an amount that is twice the amount of the transaction that is the basis of the violation.” See Economic Sanctions Enforcement Guidelines. Seventy-five percent of the civil penalties and net proceeds of forfeitures related to violation of sanctions and other criminal provisions involving designated state sponsors of terrorism go into the United States Victims of State Sponsored Terrorism (USVSST) Fund. Otherwise, civil fines are deposited into the General Fund of the U.S. Treasury. Proceeds of the remaining 25% and most other civil forfeitures for sanctions violations are deposited into the DOJ Asset Forfeiture Fund or the
Treasury Forfeiture Fund.”

OFAC Enforcement and Compliance Policies

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Improper Revenue Recognition and the SEC Whistleblower Program

On September 7, 2017, the SEC announced that financial services firm State Street agreed to pay more than $35 million to settle charges that it fraudulently charged secret mark-ups for transition management services. According to the SEC’s order, the scheme generated approximately $20 million in improper revenue for the firm. After a client discovered the overbilling scheme, State Street attempted to cover it up by blaming it on a “fat finger error.” The SEC later determined that this statement was a misrepresentation as the mark-ups were done intentionally.

We have successfully represented whistleblowers at the SEC disclosing revenue recognition fraud.  For more information about revenue recognition schemes, see our article: How to Report Improper Revenue Recognition and Earn an SEC Whistleblower Award.

If you have information that may qualify for an SEC whistleblower award, contact the Director of our SEC whistleblower practice at [email protected] or call our leading SEC whistleblower lawyers at (202) 930-5901 or (202) 262-8959. All inquiries are confidential.

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In conjunction with our courageous clients, we have helped the SEC halt multi-million dollar investment schemes, expose violations at large publicly traded companies and return funds to defrauded investors. Read our tips for SEC whistleblowers and Forbes column about the success of the SEC whistleblower program.

Contact us today to find out the strategies that we have successfully employed to secure SEC whistleblower awards for our whistleblower clients.

SEC Whistleblower Program and Revenue Recognition Fraud

Under the SEC Whistleblower Program, whistleblowers are eligible to receive an award for providing the SEC with original information about a violation of the federal securities laws, including improper revenue recognition. If the SEC uses a whistleblower’s information to bring a successful enforcement action, the whistleblower is eligible to receive 10% to 30% of the monetary sanctions collected as an award. Thus, if a whistleblower had provided original information to the SEC about State Street’s overbilling scheme, he or she could be eligible to receive an award of up to $10.5 million.

The SEC Whistleblower Program also protects the confidentiality of whistleblowers and does not disclose information that might directly or indirectly reveal a whistleblower’s identity. Moreover, whistleblowers can submit an anonymous tip to the SEC if represented by an attorney. Importantly, even compliance personnel, auditors (external and internal), accountants, officers, and directors may be eligible to receive rewards under the program.

Revenue Recognition Fraud SEC Whistleblower Awards

Since 2012, the SEC Whistleblower Office has awarded nearly $1 billion in awards to whistleblowers.  The largest SEC whistleblower award to date is $114 million. Tips from whistleblowers have enabled the SEC to take enforcement actions resulting in more than $2.7 billion in financial remedies. In fact, one tip about accounting violations that improperly inflated revenue by $80 million has already resulted in a $22 million SEC award.

For more information about the SEC Whistleblower Program, see our eBook Tips from SEC Whistleblower Attorneys to Maximize an SEC Whistleblower Award. Click below to hear SEC whistleblower lawyer Matt Stock’s tips for SEC whistleblowers:

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SEC Takes Aim at Improper Revenue Recognition

According to a Report Pursuant to Section 704 of the Sarbanes-Oxley Act of 2002, during the five years preceding the enactment of SOX, the “SEC brought the greatest number of actions [involving issuer financial-report violations] in the area of improper revenue recognition: 126 of the 227 enforcement matters involved such conduct, including the fraudulent reporting of fictitious sales, improper timing of revenue recognition, and improper valuation of revenue.” Years later, the SEC continues to focus on issuer reporting and disclosure violations, including improper revenue recognition.

According to the SEC’s 2020 Annual Report to Congress on the SEC Whistleblower Program, a majority of whistleblowers tips submitted to the SEC Whistleblower Program relate to violations with corporate disclosures and financials:

  • In FY 2011, 51 tips related to corporate disclosures and financials.
  • In FY 2012, 547 tips related to corporate disclosures and financials.
  • In FY 2013, 557 tips related to corporate disclosures and financials.
  • In FY 2014, 610 tips related to corporate disclosures and financials.
  • In FY 2015, 687 tips related to corporate disclosures and financials.
  • In FY 2016, 938 tips related to corporate disclosures and financials.
  • In FY 2017, 954 tips related to corporate disclosures and financials.
  • In FY 2018, 983 tips related to corporate disclosures and financials.
  • In FY 2019, 1,107 tips related to corporate disclosures and financials.
  • In FY 2020, 1,710 tips related to corporate disclosures and financials.

A 2016 Harvard article also found that the most common SEC enforcement actions concerning accounting violations are related to “inaccurate representations of revenue.”

As discussed in an article in CFODIVE titled Improper revenue recognition tops SEC fraud cases, the SEC continues to focus on revenue recognition fraud, and whistleblower disclosures about improper revenue recognition schemes may qualify whistleblowers for an SEC whistleblower award.

SEC Enforcement Actions for Improper Revenue Recognition

The following SEC enforcement actions are examples of the types of improper revenue recognition schemes that could qualify for an SEC award:

Fraudulent Overbilling Schemes

  • SEC v. Garthright: The SEC charged SMF Energy Corp. and its officers with accounting fraud for inflating revenues through a fraudulent billing scheme. According to the SEC’s complaint, the billing scheme “increased the amount of gallons of fuel invoiced beyond what was actually delivered to customers,” which resulted in false and misleading disclosures in the company’s SEC filings. The billing scheme circumvented SMF Energy’s internal accounting controls and led to, among other things, materially overstated revenues, profit margins, shareholders’ equity, and net income in its SEC filings. The scheme resulted in several SEC violations, including the failure to maintain a system of internal controls sufficient to ensure that its customers were charged in accordance with their respective contracts, the failure to record revenues and liabilities in accordance with GAAP, and the failure to design (or to cause others to design) disclosure controls and procedures that would have caused the company to disclose and report that it recognized revenue from improper charges to customers. The SEC disgorged all ill-gotten profits and proceeds received as a result of the actions.
  • SEC v. MedQuist, Inc.: The SEC charged MedQuist with accounting fraud when it secretly inflated customer bills by increasing the number of lines of medical test that it purportedly transcribed. According to the SEC’s complaint, the “scheme was able to continue for several years because the unit of measure upon which bills to many customers were based . . . could not be verified by customers. Knowing that its customers were unable to verify line counts on bills, [MedQuist] . . . manipulate[d] line counts on customer bills to reach specific revenue and margin targets.” MedQuist and its Director, President, and Chief Operating Officer were charged with violating securities laws.

Improper Timing of Revenue Recognition

  • SEC v. L3 Technologies, Inc.: The SEC charged L3 for failing to maintain accurate books and records and failing to maintain adequate internal controls when the company improperly recorded $17.9M in revenue from a contract by creating invoices associated with unresolved claims that were not delivered when the revenue was recorded. According to the SEC’s order, employees “immediately reported concerns regarding potential violations of L3’s accounting policies and internal accounting controls to L3’s internal ethics department,” but the subsequent ethics review failed to uncover the misconduct due, in part, to “a failure by ethics investigators to adequately understand the billing process.”
  • SEC v. Dickson: The SEC charged IGI Inc. with fraudulent accounting practices and reporting, inadequate internal controls, and books-and-records violations for engaging in fraudulent sales-cutoff practices and other improper accounting practices. As a result of the improper sales-cutoff practices, “IGI misstated its assets, revenues, and net income” for several years.
  • SEC v. Alere Inc.: On September 28, 2017, medical manufacturer Alere Inc. agreed to pay more than $13 million to settle charges that it committed accounting fraud through its subsidiaries. According to the Order, Alere’s subsidiary in South Korea improperly inflated revenues by recording sales for products that were being stored at warehouses or otherwise not yet delivered to the customers. The SEC uncovered this “bill and hold” scheme along with other improper revenue recognition practices at several other subsidiaries.
  • SEC v. Maxwell Technologies, Inc.: Maxwell Technologies paid $2.8 million as a penalty for a scheme to grow revenue by booking contingent sales of auto parts as revenue.  Evidence of the scheme included falsified purchase orders and secret side arrangements to keep the scheme hidden.

Fictitious Sales

  • SEC v. Putnam: The SEC charged Anicom Inc. and its directors with violating federal securities laws after the company falsely reported millions of dollars of nonexistent sales to inflate net income by more than $20M. According to the SEC’s complaint, Anicom included in its financial statements millions of dollars in sales to a fictitious customer, SCL Integration.

Tips for Qualifying for an Revenue Recognition SEC Whistleblower Bounty

SEC Whistleblower Lawyers Representing Revenue Recognition Whistleblowers

If you have information that you would like to report to the SEC, contact an SEC whistleblower attorney at leading whistleblower firm Zuckerman Law for a free, confidential consultation about your case by calling 202-262-8959.

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For more information about SEC whistleblower rewards and protections:

SEC Whistleblower Law Firm Representing Revenue Recognition Whistleblowers

Dodd-Frank Whistleblower Protections for Revenue Recognition SEC Whistleblowers

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If you have original information about a cryptocurrency scheme that violates SEC or CFTC rules, email us through the contact page on our website to schedule a consultation about a potential whistleblower claim.

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We represent senior professionals in high-stakes employment matters, including corporate officers, executives, managers, and partners at professional services firms.  Our clients expect clear and concise answers to their questions and a mastery of the law that enables us to quickly solve problems and formulate an effective strategy to achieve their objectives.

We pride ourselves on effective communications with clients, opposing parties, courts and administrative agencies.  Click here to read reviews from our clients.

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To help our clients understand their rights and options, we have drafted guides about some of our core practice areas.  These guides should not be relied on as legal advice.  If you are seeking legal representation, contact us at 202-262-8959 to schedule a free preliminary consultation.

 

Guide to Sarbanes-Oxley Corporate Whistleblower Protection Law

Guide to SEC Whistleblower Program and Tips for SEC Whistleblowers

Guide to Whistleblower Protection Act

 

 

 

 

 

 

 

 

 

 

See our video guides to learn more about your rights.

How to Get an SEC Whistleblower Award

Process to Qualify for an SEC Whistleblower Award

SEC Whistleblower Protections

Whistleblower Rewards and Bounties

Sarbanes-Oxley Whistleblower Protection

False Claims Act Whistleblower Rewards and Protections

Tax Fraud Whistleblower Rewards and Protections

 

Tier 1 Law Firm Representing SEC Whistleblowers

SEC Whistleblower Program Lawyers If you have information about securities fraud or other violations, contact an experienced SEC whistleblower attorney at Zuckerman Law for a free, confidential consultation by calling us at 202-930-5901 or 202-262-8959. Zuckerman Law, one of the nation’s leading law firms representing whistleblowers in whistleblower rewards and whistleblower retaliation claims, will work to quickly provide you with the highest-quality representation to maximize your likelihood of recovering and maximizing an SEC whistleblower award. We represent whistleblowers worldwide.

 

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