As companies digest the impact of Dodd-Frank's whistleblower provisions, one very common question has emerged: with millions (tens of millions? hundreds of millions?) of dollars potentially on the table for whistleblowers who provide evidence of misconduct to the SEC, how can companies incentivize employees to initially direct their complaints internally, i.e., to the company's compliance department?

The answer at one company--RAE Systems-is best summed up in the immortal words of New England Patriots wide receiver Randy Moss: "Straight cash, homie!"

The WSJ reports that RAE is fighting fire with fire, disclosing in a Form 8-K on Monday that it will be paying "FCPA bonuses" of $135,000 to "certain finance personnel" and $55,000 to its CFO, Randall Gausman. The company stated that in 2008, its internal audit department identified payments and gifts made by personnel in its operations in the People’s Republic of China that may have violated the FCPA. Following a settlement agreement with the SEC and the DOJ related to RAE's subsequent investigation, RAE's board authorized the FCPA bonuses.

RAE spokesman Lee Flanagan explained that, in fact, the bonuses were awarded to recognize the recipients' assistance in its investigation of the potentially corrupt payments made by the employees in China. Flanagan said that the recipients also helped execute new ”policies, controls and training with respect to compliance with the FCPA.”

The WSJ points out that while SEC whistleblowers might be awarded much larger awards under Dodd-Frank,"the prospect of a $55,000 bonus [from their company], without the hassle or retribution attendant to whistleblowing, might give them pause."