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conditioned upon parallel internal reporting or even cooperation by the whistleblower inconnection with internal investigations of the reported matter. In an amicus filing lastyear, the SEC asserted that the term “whistleblower” encompasses individuals whoreport suspected securities violations through internal reporting mechanisms or to theSEC itself. 25 The additional protections against retaliation offered by the Dodd-Frankwhistleblower provisions are arguably viewed as offering further encouragement toemployees to bypass internal reporting and compliance mechanisms.1. Notable Whistleblower Awards Under Dodd-FrankSignificant and telling whistleblower awards to date include the following:SEC Press Release (September 30, 2013) 26 – SEC award of more than $14 million tounidentified whistleblower whose original information led to successful enforcementaction and the recovery of “substantial investor funds.” SEC Chair Mary Jo Whitecommented that the SEC “hope[s] an award like this encourages more individuals withinformation to come forward.”SEC Release No. 72947 (August 29, 2014) 27 – SEC announces whistleblower awardof $300,000 to unnamed employee “who performed audit and compliance functions andreported wrongdoing to the SEC after the company failed to take action when theemployee reported it internally.”SEC Release No. 73174 (September 22, 2014) 28 – SEC reports largest award to dateof $30 million to whistleblower residing outside the U.S. that led to a successfulenforcement action. SEC noted this is “the fourth award to a whistleblower living in aforeign country, demonstrating the program’s international reach.”25 Brief of the SEC, Amicus Curiae In Support of the Appellant, Meng-Lin v. Siemens AG (No. 13-4385),2014 WL 3953672 (2d Cir. Feb. 20, 2014), https://www.sec.gov/litigation/briefs/2014/liu-siemens-0214.pdf.26 Order Determining Whistleblower Award Claim, Securities Act Release No. 70554, File No. 2013-4(Sept. 30, 2013), https://www.sec.gov/rules/other/2013/34-70554.pdf.27 Order Determining Whistleblower Award Claim, Securities Act Release No. 72947, File No. 2014-9(Aug. 29, 2014), https://www.sec.gov/rules/other/2014/34-72947.pdf.28 Order Determining Whistleblower Award Claim, Securities Act Release No. 73174, File No. 2014-10(Sept. 22, 2014), http://www.sec.gov/rules/other/2014/34-73174.pdf.10