The U.S. Attorney for the Southern District of New York (SDNY), Damian Williams, began the year by announcing a call for individuals with knowledge of certain criminal conduct to join Team America. The district’s latest tool in white-collar criminal enforcement, SDNY’s Whistleblower Pilot Program, is the first of its kind, offering a non-prosecution agreement (NPA) to individuals in exchange for working with SDNY prosecutors to “figure out what [they] don’t know.” See SDNY Whistleblower Pilot Program.
Williams hopes the program will alert his office to “the next Madoff case” before extensive damage occurs. The promise of an NPA under the program provides significant benefits compared with SDNY’s stringent approach to negotiating cooperation agreements. SDNY intends for its program, which applies only to individuals, to “provid[e] clarity on the requirements and the benefits of [ ] self-disclosure” to motivate individuals to provide valuable information. With the program’s greater potential for leniency, however, may also come the potential to justify imposing harsher consequences on individuals aware of criminal activity who fail to come forward.
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