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ARTICLE · 26 APRIL 2024

Whistleblower Rewards Program Update: DOJ Explains And Expands Pilot Program For Voluntary Disclosures

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On April 15, the Department of Justice (DOJ) publicly released a memorandum fleshing out its previously announced corporate whistleblower program, which is intended to induce individuals to report alleged criminal conduct...

United StatesCriminal Law
Ryan J. Meyer
Ryan J. Meyer
Ryan C. Dean
Ryan C. Dean
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On April 15, the Department of Justice (DOJ) publicly released a memorandum fleshing out its previously announced corporate whistleblower program, which is intended to induce individuals to report alleged criminal conduct, particularly by corporates, through the use of non-prosecution agreements. Indicative of the importance the DOJ is attaching to this new whistleblower program, the DOJ has publicly released this memorandum 45 days ahead of schedule! DOJ's memorandum discusses non-prosecution agreements (NPAs) generally, but the memorandum's goal is to provide clarity and assurances as to when NPAs will be offered — a process that was largely unclear until now.

While the DOJ's March 2024 announcements of the new program were focused on its potential use in generating new FCPA cases, as we predicted, health care fraud is front and center in the conduct DOJ is hunting with its new bounty program. As outlined by Principal Deputy Assistant Attorney General Nicole M.

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