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DOJ Launches Groundbreaking Whistleblower Reward Program

Posted on behalf of Arnold Law Firm on March 28, 2024 in Whistleblower

red whistleblower key on keyboardThis is the first time that the DOJ will reward whistleblowers using money forfeited in criminal actions.

On March 7, 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, the U.S. Deputy Attorney General (“DAG”), Lisa Monaco, announced the development of a new pilot program (“Program”) for the Department of Justice (“DOJ”).

The Program incentivizes individuals to report corporate misconduct by rewarding whistleblowers with payouts from civil or criminal forfeitures.

While the DOJ welcomes whistleblower reports on any violation of federal law, their primary focus would be on three key areas: (1) criminal abuses of the U.S. financial system; (2) instances of foreign corruption that fall outside the jurisdiction of the Securities and Exchange Commission; and (3) cases of domestic corruption, particularly those involving corporate payments to government officials.

The DAG’s announcement outlined the following criteria for issuing rewards:

  • Whistleblowers must provide information that is truthful and not previously known to the government;
  • eligibility for rewards is limited to whistleblowers who have not participated in the criminal activities they report; and
  • rewards are offered in cases where no other financial disclosure incentives exist, such as qui tam awards or rewards from other federal whistleblower programs.

The announcement signals “a 90-day sprint to develop and implement a pilot program, with a formal start date later this year.”

The DAG explained that while existing whistleblower programs run by various federal agencies are vital, they don’t cover the entire spectrum of corporate and financial crimes prosecuted by the DOJ. She highlighted that the DOJ intends to use the new Program in a proactive manner to fill in the gaps in these existing programs. The introduction of the Program not only generates fresh incentives for individuals to report misconduct to the DOJ but also encourages companies to enhance their internal compliance and reporting mechanisms.

This new reward Program is the DOJ’s latest step in enhancing whistleblower involvement and corporate accountability, following the recent voluntary self-disclosure programs launched by the US Attorney’s Office for the Southern District of New York and the Northern District of California.