Thoughts Regarding One Of The Recent Speeches By A DOJ Official

Prior posts here and here highlighted recent speeches delivered by DOJ Principal Deputy Assistant Attorney General Nicole Argentieri.

This post concerns Argentieri’s speech from last week and a future post will focus on Argentieri’s speech earlier this week.

It has been interesting to read some of the commentary on these recent speeches.

But then again, I read these speeches through the following lenses.

Another Day, Another DOJ Speech

It is September which means enforcement agency officials hit the “conference circuit” to give scripted speeches.

Last week it was DOJ Principal Deputy Assistant Attorney General Nicole Argentieri delivering a speech to a corporate compliance audience in New York (see here for the prior post), yesterday it was Argentieri delivering a speech to a corporate compliance event in Texas.

Argentieri began:

DOJ Principal Deputy Assistant AG Argentieri Speaks On The DOJ’s Corporate Whistleblower Awards Pilot Program

It is September which means enforcement agency officials hit the “conference circuit” to give scripted speeches.

Yesterday, it was DOJ Principal Deputy Assistant Attorney General Nicole Argentieri who delivered this speech at a corporate compliance event focused on the “newest tool in the Justice Department’s corporate enforcement toolbox: The Criminal Division Corporate Whistleblower Awards Pilot Program.”

DOJ Launches A Corporate Whistleblower Awards Pilot Program

On March 7, 2024, Deputy Attorney General (“DAG”) Lisa Monaco announced that DOJ is embarking on a “90-day sprint” to develop and implement a pilot program that will provide whistleblowers the chance to receive a monetary award in exchange for new information about “significant corporate or financial misconduct.”

The “sprint” took longer than 90 days – rather approximately 150 days – but as most runners know, longer sprint times can happen.

Earlier today, the DOJ launched a Corporate Whistleblower Awards Pilot Program. (See here, see here for 14 pages of guidance, and see here for the 4 page fact sheet).

SEC Director Of Enforcement Grewal On Cooperation

Recently Gurbir Grewal (the SEC’s Director of the Division of Enforcement) delivered this speech titled “The Five Principles of Effective Cooperation in SEC Investigations” at a securities law conference.

This post summarizes the speech and provides factual information and rebuttal points relevant to certain topics.

Grewal began as follows: