If you think your company has violated the FCPA, you should say something. However, it is important to understand the risks and rewards associated with reporting violations. First, let’s take a look at the risks of reporting to your supervisor.
If you think your company has committed an FCPA violation and you tell your supervisor, be prepared for potential repercussions; reporting anonymously to a government run whistleblower program is often a safer bet. FCPA violations are criminal, and if your supervisor or others in the company think you are accusing them of being involved, you may face retaliation or harassment, which is why it is important to enlist protection from an FCPA lawyer. Retaliation against whistleblowers can take a number of forms:
They may not promote or reward you for your efforts at work;
They could take away perks that were previously available to you;
They could even fire you because they don’t want anyone around who knows what is going on behind closed doors at work.
Even if your company has a confidential reporting hotline, most whistleblowers will tell you that it is difficult to keep your identity a secret once you report within an organization. FTI Law offers free consultations with an FCPA whistleblower lawyer to help you navigate the reporting process. In addition, if you only report internally you will not qualify for anti-retaliation protection under Dodd-Frank. Ultimately, there is a lot of downside risk for reporting internally, and virtually no upside. Hopefully, someday this will change, and companies will provide whistleblower rewards to people who report violations, but for now, reporting internally is not a course of action you should embark upon without seeking legal advice first.