US Policy and Regulatory Alert
By: Michael Culhane Harper, David C. Rybicki, Neil T. Smith, Hayley Trahan-Liptak
After months of anticipation,1 the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program).2 The Program, effective 1 August 2024, was announced at a time when federal corporate prosecutions have dipped significantly and is designed to incentivize reporting by individuals who are aware of criminal conduct.3 In remarks announcing the Program, Deputy Attorney General (DAG) Lisa Monaco stated that it shows how the DOJ is “doubling down on a proven strategy to ferret out criminal activity that might otherwise go unreported” and explained how the DOJ has worked to “fill the gaps in the patchwork” of other federal whistleblower award programs.4 DAG Monaco acknowledged that, as with any new DOJ initiative, the Corporate WB Program will be subject to regular assessments, which could lead to refinements and requests to Congress for additional statutory authorities needed to run the Program effectively.5 Introduction of the Corporate WB Program is the latest development in a multiyear effort by the DOJ to roll out an unprecedented number of corporate enforcement policy updates, pilot programs, and incentive structures designed to encourage self-reporting. The Program represents a significant escalation in risk exposure both for companies that were not previously subject to an...
A Houston-area neurosurgeon will pay $2,095,946 to resolve allegations he submitted false claims for the placement of electro-acupuncture devices, the U.S. Department of Justice announced. Dr. Raje...