This “White Collar Briefly” blog highlights a webcast that took place last week for which the archived video is already posted: “The U.S. Department of Justice’s new Whistleblower Rewards Program and its Pilot Program on Voluntary Self-Disclosures for Individuals will reshape the factors companies consider when investigating and disclosing any corporate or financial issue that may fall within DOJ’s purview. Both programs incentivize individuals who voluntarily provide the DOJ with original, nonpublic, truthful disclosures that allow DOJ to prosecute corporate wrongdoing.
The Whistleblower Rewards Program, which has not yet been detailed, will serve as a nationwide access point for individuals to report issues for potential monetary gain. The Pilot Program on Voluntary Self-Disclosures for Individuals, which is already in effect, serves as a means for corporate insiders to report on their own misconduct in exchange for leniency. Although both programs will originate under the Criminal Division, the DOJ has signaled that it may eventually apply these programs across the department. Companies are left to navigate how these new programs affect their corporate compliance programs, investigative functions, and self-disclosure analyses.”