In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to create a new whistleblower rewards pilot program.[1] The program would offer financial incentives to whistleblowers that report corporate misconduct and increase pressure on companies to voluntarily self-disclose their misconduct. In explaining the need for this program, DAG Monaco observed that existing whistleblower reporting mechanisms run by multiple U.S. agencies, while successful, were similar to a “patchwork quilt” that failed to address the full range of corporate and financial crime that DOJ prosecutes. The new pilot would thus serve as a gap-filling mechanism and create a greater level of awareness for potential whistleblowers regarding their reporting options.
After soliciting feedback regarding the program’s anticipated design from relevant stakeholders during a so-called “90-day sprint,” on August 1, 2024, DOJ’s Criminal Division released the highly anticipated Corporate Whistleblower Awards Pilot Program (the “Whistleblower Awards Pilot Program” or the “Pilot Program”). As previewed by DAG Monaco in March, the Pilot Program guidance explains that the prospect of an award is expected to incentivize individuals to report corporate criminal conduct that would otherwise go undetected or be difficult to prove. The Pilot Program is also intended...
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