Subject: File No. S7-16-18
From: Peter Sivere

August 14, 2018

"Instead, the DOJ required the company to pay $12.9 million in restitution to HP and disgorge any profits."

So the DOJ used a whistle blower's tip to collect restitution but because the SEC does not take enforcement action, the whistle blower is not eligible for an award.

The SEC even asked for the contact at the FBI, so why did the SEC not act? Had a call to the FBI not been taken, who knows if the SEC would have ever relayed the message to them or collected any restitution.

The SEC has some explaining to do to the public.

The DOJ nailed it but unfortunately for the whistle blower that does not count for being eligible for an SEC award.

https://www.schnader.com/files/Publication/7fbc43bd-13e7-42f2-8fa0-8b2866520cfc/Presentation/PublicationAttachment/5b5a5e92-55bd-4deb-b696-928e4b6ff7f7/Alert - DOJ Extends Self-Reporting Under FCPA Enforcement Policy.pdf