Department of Justice, Disclosure, SEC, Whistleblowers
More from: Andrew Good, Bora Rawcliffe, Maria Cruz Melendez, Skadden
Maria Cruz Melendez and Andrew M. Good are Partners and Bora P. Rawcliffe is a Counsel at Skadden, Arps, Slate, Meagher & Flom LLP. This post is based on their Skadden memorandum.
On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards.
Under the Program, whistleblowers who voluntarily provide the Criminal Division with original and truthful information about corporate misconduct that results in a criminal or civil forfeiture greater than $1 million are now eligible for a financial award. The award may be up to 30% of the first $100 million in net proceeds forfeited and up to 5% of any net proceeds forfeited between $100 million and $500 million.
Any award is subject to specific eligibility criteria, discussed below, and requires, among other things, a whistleblower’s cooperation. The Program complements another pilot program launched early this year that offers nonprosecution agreements to qualifying individuals who voluntarily disclose information about the same kinds of offenses.
Together, the programs reflect the DOJ’s continuing efforts to incentivize individual reporting and thus encourage companies to implement effective compliance programs and make...
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