NSO is an Israeli cyber-tech company. Company X is a company operating in Foreign Country ("FC"). FC has no official relations with Israel but Company X contacts NSO and asks to meet with a senior manager in regards to buying NSO hacking tools. The senior manager meets with Company X's manager and the Company X manager says "look, my country needs to take care of various enemies of the State. We have a choice of cyber-tech companies to choose from and NSO seems qualified but there are choices. This is a 10 year 100 million Dollar a year contract to provide our company with hacking services. As the contract is worth 1 Billion US Dollars, I would like to receive a small percentage, up front, 2% in Bitcoin. Here is my Wallet address. If you deposit the Bitcoin (worth $20 million) you will receive the contract."The NSO sales manager tells the NSO CEO and other NSO executives who authorize the sales manager to send the Bitcoin from his personal account and NSO deposits funds to enable the sales manager to buy Bitcoin and send the Bitcoins from his personal account which is done and NSO receives the contract. The NSO sales manager receives a very large bonus - $5 million USD - from NSO because the deal is closed and indeed NSO has received the first $100 million payment. The NSO sales manager takes a 2 week vacation travelling to Dubai and various cities in Europe and South America where he attends VIP parties filled with A-listers and models and clearly shows his fortune by being driven around by chauffer in rented Ferraris and Porsches and spending large amounts on gifts to his numerous new model girlfriends. People ask him how he made so much money and he relates the details of how he received his bonus.

Presume for this question that both the Securities and Exchange Commission and the United States Department of Justice are tipped off (receives information) that NSO sent $20 million in Bitcoin to the Company X manager to receive a "Bigly contract".The email continues, "NSO paid a big bribe to win this contract and I want a reward for providing this information." What legal issues will the DOJ and SEC examine to determine whether or not to file an action against NSO for a violation of the anti-bribery section of the FCPA and what are the issues regarding the request for a reward?