News & Analysis as of

Self-Disclosure Requirements Corporate Misconduct

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

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DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Foley & Lardner LLP

Understanding the Risk vs. Reward of Department of Justice’s Corporate Criminal Whistleblower Awards Pilot

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The Securities & Exchange Commission, the Department of Health & Human Services, and other agencies have long had established bounty programs that reward successful tipsters. On August 1, 2024, the Department of Justice’s...more

Orrick, Herrington & Sutcliffe LLP

DOJ announces Corporate Whistleblower Awards Pilot Program

Recently, the DOJ announced the launch of the Corporate Whistleblower Awards Pilot Program, starting on August 1. This initiative aims to address corporate crime by encouraging whistleblowers to submit original information...more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

NAVEX on

Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

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Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Bracewell LLP

Creating an Army of In-House Investigators

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In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more

Katten Muchin Rosenman LLP

DOJ Details Its Bounty Program as New Corporate Whistleblower Program Rolls Out

After teasing the release of a new corporate whistleblower program in March 2024, Deputy Attorney General Lisa Monaco and Principal Deputy Assistant Attorney General Nicole M. Argentieri each took turns announcing on August 1...more

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Lowenstein Sandler LLP

DOJ Says You Can Put the Fire Out From Inside the House: New Voluntary Self-Disclosure Program Seeks to Root Out Corporate Crime...

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Introduction: On April 15, 2024, the Department of Justice’s (DOJ) Criminal Division announced a new Pilot Program on Voluntary Self-Disclosure for Individuals. Under this program, individuals who voluntarily disclose certain...more

NAVEX

Navigating the DOJ’s New Pilot Program

NAVEX on

In a bold move, the U.S. Department of Justice (DOJ) launched a pilot program designed to encourage corporate executives to disclose information about financial misconduct within their organizations. Through this initiative,...more

Jenner & Block

Client Alert: DOJ Continues Its Trend of Strengthening Incentives to Report Corporate Misconduct

Jenner & Block on

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...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

Snell & Wilmer on

Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

Bradley Arant Boult Cummings LLP

Criminal Division’s new voluntary self-disclosure program still uncertain and risky

On April 15, 2024, the Department of Justice released its “Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals.” Similar in many ways to programs introduced earlier this year by the U.S. Attorney’s...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Launches New Pilot Program to Allow Whistleblowers Who Report Financial Crimes, Corruption to Avoid Prosecution

On April 15, 2024, the U.S. Department of Justice (DOJ) Criminal Division launched a new pilot program to enable whistleblowers to avoid prosecution when they voluntarily report new information to federal law enforcement...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

Polsinelli on

On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Jones Day

DOJ Criminal Division Offers Non-Prosecution Agreements to Individuals Who Voluntarily Report Corporate Wrongdoing

Jones Day on

The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more

Perkins Coie

DOJ Pilot Program Changes the Calculus on Corporate Self-Disclosure

Perkins Coie on

The Criminal Division of the U.S. Department of Justice (DOJ) announced a Pilot Program on Voluntary Self-Disclosures for Individuals (Pilot Program) on April 15, 2024. Under the new policy, individuals who were involved in...more

Epstein Becker & Green

The Department of Justice’s Criminal Division Launches a Pilot Program on Voluntary Self-Disclosures for Individuals

Epstein Becker & Green on

Since October 2021, the Department of Justice (DOJ) has been implementing a variety of changes to its corporate criminal enforcement policies. These efforts all reflect DOJ’s focus on individual accountability, punishing...more

Mintz

Another Declination from DOJ’s Criminal Division Emphasizes the Continued Focus on Voluntary Self-Disclosure in 2024

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Guidepost Solutions LLC

A “Quick Guide” to Government Whistleblower and Voluntary Self-Disclosure Programs: Heed the Warning from DOJ to Strengthen...

The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to...more

BCLP

New DOJ Pilot Program Incentivizes Individuals to Report Criminal Conduct

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Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...more

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