On August 1, 2024, the Department Department of Justice (DOJ) launched a three-year Whistleblower Pilot Program designed to reward individuals who provide original and truthful information about specific types of corporate misconduct that result in successful asset forfeiture. Deputy Attorney General Lisa Monaco highlighted the long-standing practice of using rewards to coax tipsters into exposing wrongdoing, akin to the “Wanted” posters of the Old West. Besides offering monetary compensation to whistleblowers, the DOJ amended its Corporate Enforcement and Voluntary Self-Disclosure Policy, allowing companies to receive full voluntary self-disclosure benefits if they self-report misconduct within 120 days of an internal report, and before the DOJ contacts them. This revised policy aims to encourage preemptive self-reporting by corporations.
DAG Monaco pointed out that existing whistleblower programs run by the Securities and Exchange Commission (SEC) and other regulatory bodies form a “patchwork quilt” of coverage, failing to address the entire spectrum of corporate and financial misconduct prosecuted by the DOJ. The new Whistleblower Pilot Program focuses on gaps in four specific areas: nonregulated financial institutions, foreign corruption involving privately held companies, domestic corruption violations, and healthcare fraud schemes targeting private insurers or nonpublic benefit programs. As such, the DOJ aims to create comprehensive coverage for corporate and financial wrongdoing. For more details, refer to the original article.