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Wednesday, November 27, 2024

DOJ Whistleblower Pilot Program: Transforming the Compliance Landscape - JD Supra

In a world where corporate integrity and accountability are more crucial than ever, the Department of Justice (DOJ) ‘s Whistleblower Pilot Program announcement marks a pivotal moment for compliance professionals. This initiative promises to reshape how we approach whistleblowing, corporate misconduct, and organizational culture. Let’s dive into the details and implications of this program, focusing on how it impacts compliance officers, whistleblowers, and corporate governance.

Deputy Attorney General Lisa Monaco said of the Whistleblower Pilot Program, “With this program, we’re doubling down on a proven strategy to ferret out criminal activity that might otherwise go unreported. Law enforcement has long offered rewards to coax tipsters to report crimes — from the “Wanted” posters of the Old West to the reforms in Dodd-Frank that created whistleblower programs at the SEC and the CFTC.” However, she cautioned, “those programs — by their very nature — are limited in scope. They only cover misconduct within those agencies’ jurisdictions. The same is true for similar programs run by the IRS and FinCEN. And qui tam actions, which offer whistleblowing incentives, are available only for fraud against the government.” The DOJ “corporate enforcement program is rooted in using carrots and sticks. Today’s announcement builds on our other efforts to incentivize reporting of corporate misconduct to the government.” Part of those carrots is to reward those “under these disclosure...



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