circumstances were present: (1) a corporation voluntarily and fully at the earlier reporting date , thus preserving their “place in line” for disclosed the potential misconduct; (2) corporate principles voluntarily a possible whistleblower award from the SEC; and (3) provide that a engaged in interviews with DOJ and provided truthful and complete whistleblower’s voluntary participation in an entity's internal compliance information about their conduct; (3) a parent company conducted and reporting systems is a factor that can increase the amount of an extensive pre-acquisition due diligence of potentially liable subsidiaries award, and that a whistleblower’s interference with internal compliance and engaged in significant remediation efforts post-acquisition; (4) a and reporting system is a factor that can decrease the amount of an award. company provided information about its extensive compliance policies, See Exchange Act Rule 21F, 17 C.ER. § 240.21F, procedures, and internal controls; (5) a company agreed to a civil 36 See Exchange Act Rule 21F-7(b), 17 C.ER. § 240.21F-7(b). resolution with the Securities and Exchange Commission while also 7 For example, SEC staff will not disclose a whistleblower’s identity in demonstrating that criminal declination was appropriate; (6) only a single response to requests under the Freedom of Information Act. However, employee was involved in the improper payments; and (7) the improper there are limits on SEC’s ability to shield a whistleblower’s identity, payments involved minimal funds compared to overall business revenues. and in certain circumstances SEC must disclose it to outside entities. 38 See Criminal Information, United States v. Peterson, supra note 8, For example, in an administrative or court proceeding, SEC may be Press Release, U.S. Dept. of Justice, Former Morgan Stanley Managing required to produce documents or other information that would Director Pleads Guilty for Role in Evading Internal Controls Required reve