A couple of unrelated enforcement items have come together to lead me to this question: Given the new whistleblower bounties available under Dodd-Frank to people who provide the SEC with original information leading to a successful enforcement action, will we now start to see a surge of competitors ratting each other out for fraud, bribery, etc.?

I ask this after first reading the SEC's announcement last month that it has awarded a $1 million bounty to Karen Kaiser for providing information leading to the collection of civil penalties in the SEC's insider trading case against Pequot Capital Management, Inc. Among the defendants sued by the SEC based on Kaiser's information was David Zilkha, a Pequot employee who was Kaiser's ex-husband.

I don't claim to have any insight into the current relationship between ex-spouses Kaiser and Zilkha, but if it resembles that of some of the divorced couples I know, I suspect that finding a way to get her ex-husband sued and for herself to simultaneously receive $1 million dollars in the process was one of the happier days in Ms. Kaiser's life.

I next read an article about a company called NewMarket Corp. that is accusing a competitor, Innospec, of "bribing Iraqi and Indonesian officials to ensure the failure of a field test, causing NewMarket to lose out on lucrative deals in both countries." NewMarket's case against Innospec is based on facts laid out in the recent global corruption settlement Innospec agreed to with the DOJ, SEC, and others, but if it had, hypothetically, learned of the alleged bribery on its own it could now be a whistleblower under Dodd-Frank.

So is my NewMarket hypothetical above the commercial equivalent of the angry ex-spouse situation? Will companies that learn of fraud by competitors now leap at the chance to damage their competitor and enrich themselves through the Dodd-Frank whistleblower bounty program?