Earlier this month, the Department of Justice (DOJ) launched its anticipated Criminal Division Corporate Whistleblower Awards Pilot Program (the “Pilot Program”), which went into effect on August 1, 2024, and will continue for three years. As Deputy Attorney General (DAG) Lisa Monaco explained earlier this year, the Pilot Program is intended to provide a monetary incentive for individuals with knowledge of nonpublic corporate wrongdoing to report the misconduct. It follows a series of recent policy changes announced by DOJ, including to its Corporate Voluntary Self Disclosure Policy (the “Corporate VSD Policy”) and Pilot Program on Voluntary Self Disclosures for Individuals, which have been described by DAG Monaco as “a mix of carrots and sticks to promote responsible corporate citizenship.” Notably, under the amended Corporate VSD Policy, companies are eligible for a presumption of a declination (i.e., no criminal charges) if they self-report information received by an internal whistleblower to DOJ within 120 days.
These programs reflect DOJ’s focus on combatting corporate crime and fraud across many industries and they supplement existing policies that address the health care industry, such as the DOJ’s False Claims Act Reporting Program, the Health and Human Services Office of Inspector General’s (OIG) Whistleblower Protection Program, and the Centers for Medicare & Medicaid Services’ (CMS) Self-Referral...
Topline Alexander Smirnov, the former FBI informant who was accused earlier this year of making false statements about President Joe Biden and his son Hunter Biden, was indicted Tuesday on unrelate...