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DOJ Corporate Whistleblower Awards Pilot Program - JD Supra

by Jonathan Barr
Fri, Aug 9, 2024 13:33 ET
in Employment News, Press Release

  • As foreshadowed by Deputy Attorney General Lisa Monaco during the ABA White Collar Crime conference last March,[1] on August 1, 2024. the Department of Justice’s (DOJ or Department) Criminal Division launched the Corporate Whistleblower Awards Pilot Program (Pilot Program). Under this three-year Pilot Program, an eligible whistleblower who provides the Criminal Division with original and truthful information about certain corporate misconduct that results in a civil or criminal forfeiture in excess of $1 million may be eligible for a significant share of the forfeited proceeds. Awards are entirely discretionary and are not guaranteed.
  • DOJ structured the Pilot Program to support the internal reporting of violations through a company’s internal compliance program by making it clear that employees who report misconduct internally remain eligible to receive an award as long as they submit information to DOJ within 120 days of the initial internal report to the company. The Pilot Program also provides that a whistleblower’s participation in internal compliance systems by reporting the issue first may be a factor that increases an award.
  • Importantly for companies, DOJ temporarily amended the Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (Corporate Enforcement Policy), allowing qualifying companies to receive the benefits of traditional self-disclosure, including a presumption of declination, even where an employee has made a whistleblower report...


Read Full Story: https://news.google.com/rss/articles/CBMigwFBVV95cUxPM1lDaXZmUE9ZVERrbTZYNlBG...


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