On April 15, 2024, the Department of Justice (DOJ) criminal
division announced a new pilot program designed to reward
individuals with non-prosecution agreements (NPAs) who voluntarily
self-disclose "actionable, original information"
regarding a corporation's "criminal conduct that might
otherwise go undetected or be impossible to
prove."1 The DOJ's release comes on the heels
of Deputy Attorney General Lisa Monaco's March 7, 2024
announcement, detailing DOJ's forthcoming whistleblower rewards
program for civil and criminal forfeitures.2 Both
programs provide incentives for individuals to report misconduct
directly to the DOJ first (for pecuniary and/or self-preservation
purposes) instead of first utilizing a company's internal
reporting channels. Companies should therefore be aware that
self-reporting might be a race against their own employees for
voluntary self-disclosure (VSD) credit.
