Yesterday, the Department of Justice (DOJ) and the National Fraud Enforcement Division announced the Fraud Whistleblower Incentive Program (WHIP), a three-year pilot program that provides fixed payments of $10,000 to $30,000 for qualifying tips that lead to criminal charges in specified fraud categories, including health care and certain federal benefit programs. According to DOJ, the Department of the Treasury is committing $25 million to support the program.

The Upshot

• Early-stage payments tied to charging decisions. WHIP is designed to pay rewards after DOJ files and unseals an indictment, information, or criminal complaint, rather than after final resolution, and the program does not impose a minimum loss threshold.
• Limits for compliance and senior personnel, with defined exceptions. Officers, directors, and personnel with compliance or internal audit responsibilities are generally excluded from eligibility based on how they obtained the information, but the guidance describes exceptions, including circumstances where disclosure is needed to prevent certain imminent harms or obstruction and where at least 120 days have elapsed after internal reporting to specified recipients.
• Company conduct may affect cooperation credit and enforcement risk. DOJ may consider retaliation against a reporting individual, or efforts to impede communications with DOJ (including enforcing or threatening to enforce certain confidentiality agreements), when evaluating cooperation...

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