Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy Attorney General, (“DAG”) Lisa Monaco, and yet its official launch offers potentially profound implications for companies and their compliance programs. It is the third initiative by DOJ in recent years to further incentivize companies and individuals to self‑report potential criminal conduct:

• In January 2023, DOJ revised the Criminal Division’s Corporate Enforcement and Voluntary Self‑Disclosure Policy (“CEP”) to, among other things, further incentivize companies to voluntarily self‑disclose “immediately upon the company becoming aware of the allegation of misconduct”; and
• In October 2023, DAG Monaco announced the M&A Safe Harbor Policy, intended to incentivize acquiring companies to promptly self‑disclose misconduct that they discover within an acquired entity, and to fully remediate such misconduct within a baseline period.

Now, with the Pilot Program, DOJ is aligning with other U.S. agencies, including the U.S. Securities and Exchange Commission (“SEC”), the U.S. Commodities and Futures Trading Commission (“CFTC”), and the Financial Crimes Enforcement Network (“FinCEN”), that have introduced whistleblower incentive programs to notable success.[1] (see Annex A). Nonetheless, as arguably the most influential enforcement agency, particularly for...

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