On January 10, 2024, US Attorney Damian Williams announced a new Whistleblower Pilot Program for the US Attorney’s Office of the Southern District of New York (SDNY). The program is designed to proactively uncover criminal conduct and boost enforcement efforts by encouraging individuals to self-disclose criminal conduct. Provided certain conditions are met, a self-disclosing individual will be eligible for a non-prosecution agreement (NPA), pursuant to which the SDNY would agree not to prosecute that individual for the disclosed conduct. Traditional whistleblower programs, administered by agencies like the Securities Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Internal Revenue Service (IRS), and Financial Crimes Enforcement Network (FinCEN), encourage individuals to report credible information of illegal activity by offering the opportunity for financial rewards, which can be substantial, for whistleblowers under the right circumstances, as well as strong anti-retaliation protections. Unlike these whistleblower programs, SDNY’s new program is not designed to offer financial rewards for self-disclosures, but rather solely offers the possibility of protection from prosecution. In that regard, the policy is more akin to a self-disclosure program, such as the Voluntary Self-Disclosure Program announced by the Department of Justice (DOJ) on February 22, 2023, than a typical whistleblower program. This unique pilot program is the first instance of a...
; ; ; agreed to pay $17.07 million to settle federal allegations of illegal diversity, equity and inclusion (DEI) hiring practices on Friday, marking the Justice Department's first resolution unde...