Clifford Chance

Hear the Whistle Blow: DOJ's New Whistleblower Pilot Program Tracks the Regulatory Crescendo Towards Voluntary Disclosure

August 5, 2024

On August 1, 2024, the U.S. Department of Justice unveiled the details of its much-anticipated Corporate Whistleblower Awards Pilot Program intended through individual financial incentives to help root out corporate misconduct and to encourage companies to make prompt, voluntary disclosures. The Pilot Program, designed by the DOJ's Criminal Division, is part of a whole-of-government effort to convince corporations—and also individuals—to be the "first in the door" to notify the appropriate authorities of both civil and criminal violations once discovered, using a mix of carrots and sticks to do so. The Pilot Program, a three-year initiative effective immediately, bolsters the DOJ's crackdown on corporate misconduct.

The Pilot Program seeks to fill some of the gaps left by other whistleblower reward programs and will qualify individuals meeting the criteria that disclose new information regarding four specific types of corporate criminal activity to the DOJ to receive a percentage of any resulting forfeiture as a monetary award.

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