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The shudder felt in C-suites across the country in late July was not an earthquake, but the trembling of corporate executives and general counsels contemplating back-to-back events that could presage a much more aggressive approach to securities law violations by the Securities and Exchange Commission and the Commodity Futures Trading Commission. The Dodd-Frank financial reform bill signed into law on July 22 includes a provision that mandates the SEC, as well as the CFTC, to award a bounty of 10% to 30% to any whistleblower who provides significant information about securities fraud involving a public company, or even a private company owned by a public company, that results in a judgment in excess of $1 million.

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