On March 7, 2024, Deputy Attorney General (DAG) Lisa Monaco announced the contours of a new Department of Justice (DOJ) pilot program (Pilot) offering financial incentives to individual whistleblowers who report certain criminal conduct to the DOJ. This significant announcement came in a speech that emphasized individual accountability for corporate conduct, more significant sanctions for recidivist corporations, expansion of credit for voluntary self-disclosures (VSDs), and a focus on prosecution of misconduct aided by artificial intelligence. (Acting Assistant Attorney General (AAG) Nicole M. Argentieri expanded on DAG Monaco’s comments on March 8, 2024.) As with corporate VSDs, after satisfying other prerequisites, the Pilot—designed to formalize the DOJ’s previously ad hoc approach with something more akin to the whistleblower compensation programs arising from the Dodd-Frank Act—rewards only the first reporter of misconduct, further setting the table for a race to the DOJ. As DAG Monaco said, “When everyone needs to be first in the door, no one wants to be second.”
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