On August 1, 2024, Deputy Attorney General Lisa Monaco unveiled the Department of Justice’s new . The announcement marks the conclusion of the Department’s previously announced “sprint” towards a pilot program, as DAG Lisa Monaco first previewed back in March of this year.
Under this three-year pilot, whistleblowers who voluntarily provide DOJ with “original” information that leads to a successful corporate prosecution may be rewarded with a share of the resulting forfeiture. As detailed in a fact sheet released in parallel with the announcement, DOJ views the program as instrumental towards a number of key objectives, among those: filling gaps in existing federal whistleblower programs; “supercharging” DOJ’s corporate investigations efforts; complementing DOJ’s existing tools for corporate accountability; and further incentivizing corporate investment in robust compliance programs and internal reporting systems.
Criteria and Caveats with a Focus on Corruption, Financial Institutions, and Healthcare Fraud
The pilot program is limited to misconduct involving: (1) certain crimes involving financial institutions, from traditional banks to cryptocurrency businesses; (2) foreign corruption involving misconduct by companies, including violations under the Foreign Corrupt Practices Act, Foreign Extortion Prevention Act, and violations of the money laundering statutes; (3) domestic corruption involving payment of bribes of kickbacks to public officials; or (4) health care fraud...
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