This blog post was drafted with assistance from Sean C. Church, Paralegal
On Thursday, August 1st, the Department of Justice announced a new Corporate Whistleblower Awards Pilot Program to “uncover and prosecute corporate crime.” This new program incentivizes whistleblowers with potentially very significant payouts if they provide the Criminal Division with original and truthful information about corporate misconduct, including reports of certain trade compliance violations. With this program, companies face higher risk that employees may report legal violations to the government because of the potential financial reward. We recommend that companies reexamine their trade compliance and other policies and revise them as needed to encourage employees to notify company officials, internal legal, or company trade compliance teams to potential concerns regarding non-compliance with company policies and applicable laws. This is a good opportunity to review and update company policies.
The information provided by a whistleblower must relate to one of the following areas:
a. Violations by financial institutions, their insiders, or agents, including schemes involving money laundering, anti-money laundering compliance violations, registration of money transmitting businesses, and fraud statutes, and fraud against or non-compliance with financial institution regulators (such as OFAC).
b. Violations related to foreign corruption and bribery by, through, or related to companies,...
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