The U.S. Department of Justice (DOJ or the Department) announced its much-anticipated Corporate Whistleblower Awards Pilot Program on August 1, 2024. This three-year pilot will, for the first time outside of the False Claims Act context, compensate whistleblowers who report to federal prosecutors original information about significant corporate misconduct. In connection with this announcement, DOJ also introduced a 120-day deadline by which companies that are notified internally of potential misconduct and are not first in the door at DOJ must self-report to remain eligible for a presumption of a declination of prosecution.

Because these announcements potentially affect both the timing and scope of internal investigations, as well as decisions on when and whether companies should self-disclose potential misconduct to DOJ, in-house counsel and their outside legal advisors should get up to speed on these new developments.

Overview of the Corporate Whistleblower Awards Pilot Program

Under DOJ’s three-year Pilot Program, whistleblowers who provide the Department with original information that leads to criminal or civil forfeiture exceeding $1 million may be eligible for financial compensation. However, to be eligible for an award, the whistleblower must first meet several criteria, including the following:

1. Eligibility. The whistleblower cannot be a foreign government official or an official, employee, or contractor (or immediate relative or household member thereof) of DOJ...

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