DOJ Strengthens Incentives to Report Corporate Misconduct
Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize disclosure of alleged corporate wrongdoing: the Pilot Program on Voluntary Self-Disclosures for Individuals. The launch of this program is the latest in a string of new programs […]
Carolyn Small is Special Counsel, Paige Zielinski is an Associate, and Brandon Fox is a Managing Partner at Jenner & Block LLP. This post is based on a Jenner & Block memorandum by Ms. Small, Ms. Zielinski, Mr. Fox, Laurel Loomis Rimon, David Bitkower, and Anthony Barkow.
Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize disclosure of alleged corporate wrongdoing: the Pilot Program on Voluntary Self-Disclosures for Individuals. The launch of this program is the latest in a string of new programs that are designed to incentivize individuals to report corporate wrongdoing and cooperate with the government when it investigates and prosecutes companies for certain criminal violations. Below, we provide an overview of the new program and criteria for participation, and discuss the government’s growing emphasis on encouraging self-disclosures and implementing whistleblower programs to identify potential criminal violations by public and private companies.
