In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot Program" (the Whistleblower Program) went into effect on August 1, 2024. Individuals can now submit "original and truthful information" directly to the DOJ's Criminal Division for potential reward for covered conduct. Specifically, the program covers certain financial crimes, public corruption, and private program health care fraud that were not previously subject to existing programs.

If a whistleblower's report results in the successful prosecution of any companies and/or individuals, that whistleblower may receive a portion of any forfeiture the DOJ secures – whether through a criminal or civil action. The Whistleblower Program is designed to "fill important gaps in existing federal whistleblower programs," so companies active in areas not subject to scrutiny through pre-existing whistleblower programs (i.e., by the SEC or FinCEN, or pursuant to the False Claims Act) should ensure that their compliance programs are robust and effective to mitigate future risk in light of the new Whistleblower Program.

I. The Corporate Whistleblower Awards Program

Initially, the DOJ seeks to focus on the following areas, which are not subject to existing federal whistleblower programs:

1. "Certain crimes involving financial institutions and their employees;
2. Foreign...

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