On August 23, 2024, the US Attorney’s Office for the Central District of California, which is the largest judicial district in the United States, announced a new Voluntary Self-Disclosure and Whistleblower Pilot Program. The Whistleblower Program is designed to incentivize individuals to report corporate crime and financial fraud to the government and, in turn, increase the pressure on companies to voluntarily self-disclose misconduct. In exchange for full cooperation with the investigation, whistleblowers may be able to avoid prosecution for their own misconduct and obtain a non-prosecution agreement (NPA) or deferred prosecution agreement (DPA).[1]
This Whistleblower Program follows on the heels of the US Department of Justice (DOJ) announcing the details of its Corporate Whistleblower Awards Pilot Program. Other US Attorney’s Offices, including the Southern District of New York and Northern District of California, also announced similar whistleblower programs earlier this year. These whistleblower programs are the latest example of DOJ’s increased focus on investigating and prosecuting corporate crime.
The stated purpose of the Central District of California’s Whistleblower Program is to “encourage early voluntary self-disclosure and promote effective enforcement of criminal laws.”
First, the...
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