As usual, the U.S. Attorney’s Office for the Southern District of New York (the “SDNY”) is on the hunt for fraudsters and other white collar criminals. Though the Department of Justice has rewarded corporations for self-reporting to and cooperating with it, the SDNY recently took an important step in providing a meaningful incentive to individuals who self-report financial fraud and public corruption. On January 10, 2024, U.S. Attorney Damian Williams announced the launch of the SDNY Whistleblower Pilot Program. The policy represents a marked departure from the manner in which the SDNY has historically treated cooperators and is designed to encourage early voluntary disclosure of criminal conduct by individual participants in certain non-violent offenses. While only time will tell whether the program is successful in incentivizing whistleblowers to cooperate early and often, it may serve as a test case for other jurisdictions looking to adopt similar programs.
The policy applies to individuals who disclose to the SDNY information regarding criminal conduct committed by or through public or private companies, exchanges, financial institutions, investment advisers or investment funds involving fraud, corporate control failures, bribery or fraud relating to federal, state or local funds. Under the pilot program, the SDNY will enter into a non-prosecution agreement (“NPA”) with a qualifying individual who cooperates with the SDNY by furnishing it...
False sexual or rape allegations can have devastating consequences for the accused, including reputational damage, loss of employment and emotional trauma. In Nigeria, current legislation focuses ...