The Securities & Exchange Commission, the Department of Health & Human Services, and other agencies have long had established bounty programs that reward successful tipsters. On August 1, 2024, the Department of Justice’s (DOJ) Criminal Division joined these other agencies, launching a three-year Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). The Pilot Program marks a significant effort by DOJ to enhance its ability to fight corporate crime by enlisting whistleblowers to aid in the effort. While there is some skepticism as to the Pilot Program’s potential success, there is no doubt it presents new challenges for companies. This article provides an overview of the Pilot Program as well as guidance for companies subject to its framework.

Overview of Program

The Pilot Program provides a bounty for successful tips relating to “possible violations of law” for four categories of crimes: (1) foreign corruption and bribery; (2) financial institution crimes; (3) domestic corporate corruption; and (4) health care fraud involving private insurance plans. DOJ press focuses on these four areas, though the intake form provides a fifth “other” option for a reporter to select.

Eligibility & Key Terms

To be eligible, whistleblowers must provide original, non-public, and truthful information of a possible violation of law that leads to a successful forfeiture exceeding $1 million. Legal, audit, and compliance personnel are presumptively ineligible, and...

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