On August 1, 2024, the U.S. Department of Justice (“DOJ”) officially unveiled its Corporate Whistleblower Awards Pilot Program (the “Program”). The three-year pilot program aims to broaden the range of corporate misconduct that may lead to rewards for individuals who report to the government. Like other government whistleblower rewards programs, the Program is designed to incentivize both the reporting of corporate criminal wrongdoing by individuals seeking monetary rewards and the voluntary disclosure of information by companies seeking to maximize the potential benefits of voluntary disclosure and cooperation under the DOJ’s Corporate Enforcement Policy (“CEP”).
In order to be eligible for an award under the Program, an individual must provide the DOJ with original, truthful information in writing about criminal misconduct relating to one or more designated program areas that leads to a criminal or civil forfeiture exceeding $1 million in connection with a successful prosecution, corporate resolution, or forfeiture action. “Original information” is defined in the DOJ’s Program guidance and must be, among other criteria, information derived from an individual’s independent knowledge or analysis that is non-public and not previously known to the DOJ.
Consistent with prior statements by DOJ officials, the Program is intended to fill gaps in the coverage of existing government rewards programs, including the DOJ’s qui tam program and the whistleblower rewards programs of...
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