In Short
The Development: On August 1, 2024, the
Department of Justice's ("DOJ") Criminal Division
announced its Corporate Whistleblower Awards Pilot Program
("Pilot Program"), designed to reward whistleblowers who
report information about corporate misconduct that results in a
successful forfeiture, as well as a corresponding amendment to the
Corporate Enforcement and Voluntary Self-Disclosure
("VSD") Policy.
The Background: The Pilot Program follows
similar programs by the Securities and Exchange Commission
("SEC"), Commodity Futures Trading Commission
("CFTC"), and Financial Crimes Enforcement Network
("FinCEN"). It is designed to "fill the gaps"
left by these programs by focusing on four areas: (i) certain
crimes involving financial institutions; (ii) foreign corruption;
(iii) domestic corruption; and (iv) health care fraud schemes
targeting private insurers not subject to qui
tam recovery under the False Claims Act.
