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VI.Dodd-Frank Anti-Retaliation ProvisionsSection 922 of the Dodd-Frank Act applies to publicly traded companies and providesnew incentives to whistleblowers to report corporate malfeasance. 41The incentivesinclude provisions for bounties and an anti-retaliation provision. The anti-retaliationprovision prohibits employers from taking adverse actions against a whistleblower who:(1) provides information to the SEC; (2) initiates, testifies in, or assists in aninvestigation of the SEC related to such information; or (3) makes disclosures requiredunder SOX or the Securities Exchange Act or other rule or regulation subject to theSEC’s jurisdiction. 42The bounty provision requires the SEC to pay whistleblowersbetween 10% and 30% of collected monetary sanctions for voluntarily providing originalinformation in a successful SEC enforcement action which results in the collection of atleast $1 million in sanctions. 4341 In October, 2014, the Second Circuit Court of Appeals found that the anti-retaliation provisions of Dodd-Frank do not apply to a non-citizen employed abroad by a foreign company. The case involved aTaiwanese citizen who reported Siemans China for alleged violations of the Foreign Corrupt PracticesAct. The employee alleged he was demoted then fired in retaliation for making the complaint. See LiuMeng-Lin v.. Siemens AG, 763 F.3d 175 (2d Cir. 2014).42 There is a debate over whether or not a report made only internally will suffice. See Asaid v. G.E.Energy United States, LLC, 720 F.3d 620 (5 th Cir. 2013). In Asaid, the purported whistleblower filed acomplaint alleging that G.E. Energy violated Dodd-Frank’s whistleblower protection provision when itfired him following his internal reports of possible Foreign Corrupt Practices Act violations which hemade to his supervisor. The Fifth Circuit upheld the dismissal of the complaint, holding that the Dodd-Frank whistleblower protection provision is limited “…to those individuals who provide informationrelating to a violation of the securities laws to the SEC.” Id. at 630. See also Banko v. Apple Inc., No.13-CV-02977, 2013 U.S. Dist. LEXIS 149686 (N.D. Cal. Sept. 27, 2013) and Wagner v. Bank of AmCorp., No. 12-CV-00381, 2013 U.S. Dist. LEXIS 101297 (D. Colo. July 19, 2013). But see Yang v.Navigators Group, Inc., 18 F. Supp. 3d 519 (S.D.N.Y. 2014), wherein the court refused to dismiss anaction brought by a purported whistleblower who only made an internal report of suspected securitieslaw violations. The court rejected the analysis of the Fifth Circuit, deferring to the SEC’s interpretationand holding that the “…statute does not clearly and unambiguously limit whistleblower protection toindividuals who report violations to the SEC….” Id. at 533. See also Azim v. Tortoise Capital Advisors,LLC., No. 13-2267-KHV, 2014 U.S. Dist. LEXIS 22974 (D. Kan. Feb. 24, 2014).43 12 U.S.C. §5567.