Louise Delahunty and Nicholas Storrs Author SEC Bounty Program Article in The Lawyer

October 15, 2012

On October 15, The Lawyer published the article, “Shadow of the Bounty Hunter,” co-authored by Ms. Delahunty and Mr. Storrs. The article examined the power of the Securities and Exchange Commission’s whistleblowing bounty scheme, which was implemented as part of the Dodd-Frank Act and uses company employees to detect fraud and corruption within their company in return for an award of up to 30 percent of the total fine. The authors discussed the challenges these measures present to international companies, including U.K. companies that are even minimally connected to the United States. The article underscored the importance for companies to implement strong compliance programs given the existence of bounty payments. The authors also questioned how far one should go to detect crime and whether a criminal justice tool should award money to employees who come forward.