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compliance and audit staffer who provided a tip to the SEC that ultimatelyled to an enforcement action. (The Dodd-Frank whistleblower provisionrequires a 10% to 30% payout to the whistleblower of collected sanctionsof more than $1 million dollars.) 2• An ex-Vanguard Group, Inc. attorney filed a $1 billion dollar whistleblowerlawsuit in August, 2014, alleging that he was terminated by Vanguard afterhe alleged that the company failed to pay taxes and file tax returns forseveral years in New York. 3• The SEC awarded three whistleblowers nearly $15 million dollars underthe Dodd-Frank whistleblower program. A complaint was filed as a resultof a dispute amongst the three individuals over the allocation of the awardin June, 2014. 4• In October 2014, the SEC awarded 30 million dollars to a non-US citizenwho reported a fraud that would otherwise have gone undiscovered. Therecipient was not a compliance officer, but the award is the largest ever ofDodd-Frank's 14 such awards to date. With this sort of money in play,loyalty may be in short supply. 5• An employee sentenced to 2-1/2 years in federal prison still walked awaywith $104 million dollars after being awarded such by the I.R.S. 62 Ed Beeson, SEC Strikes Fear with First Award to Compliance Pro, (Sept. 03, 2014), www.law360.com3 Kirsten Grind, Vanguard Case Tests Rights of Lawyer Whistleblowers, Wall Street Journal, Aug. 08,2014.4 See Tung v. Sears, No 14-CV-4699, complaint filed (N.D.Ill. June 23, 2014).5 Rachel Louise Ensign, SEC to Pay $30 Million Whistleblower Award, its Largest Yet, Wall Street Journal,Sept. 22, 2014.6 David Kocieniewski, Whistleblower Awarded 104 Million by IRS, New York Times, Sept. 11, 2012.