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Upcoming DOJ Whistleblower Program – How Will This Work?

questions to ask

Recently, DOJ officials announced a new upcoming whistleblower program (see here and here for prior posts).

This post ponders a few questions about how the whistleblower program will actually work in connection with Foreign Corrupt Practices Act and Foreign Extortion Prevention Act enforcement actions – two areas in which DOJ officials have said they are “especially interested” in receiving information about.

In pertinent part, Deputy Attorney General Lisa Monaco stated:

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Am I A Victim?

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As highlighted in this recent DOJ release, the CEO of a multinational corporation was criminally charged for giving, offering, and promising money to a Marine Liaison Officer for the U.S. Navy’s Fifth Fleet in Manama, Bahrain in exchange for the officer using his official position to take action benefiting the corporation.

As highlighted in this recent DOJ release, “a former City of Atlanta Commissioner of Watershed Management was sentenced today to four and a half years in prison for accepting bribes from an Atlanta contractor in exchange for steering city business worth millions of dollars to the contractor’s company.”

Numerous other DOJ press releases could also be highlighted regarding bribery of “U.S. officials” who abused their positions of authority and trust for their own personal enrichment and place their interests ahead of the public interest.

I am a U.S. citizen.

Am I thus a victim of this criminal conduct?  Do I deserve compensation?  Does my community deserve a new school or playground?

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Glencore Acknowledges A Victim, But Disputes The Amount Of Restitution Owed


As highlighted in this prior post, in connection with the May 2022 Glencore FCPA enforcement action, the majority owners of Crusader Health (Ian and Laureth Hagen) petitioned the court in the underlying enforcement action to file a restitution claim under the Mandatory Victims Restitution Act and the Crime Victims Act on the basis that the entity was a victim of Glencore’s conduct in the Democratic Republic of Congo. The court granted the petition.

Recently, Glencore acknowledged “that Crusader—and by extension, the Hagens—was harmed by the offense to which Glencore has pled guilty, and it is prepared to pay restitution in the amount of any loss directly and proximately caused by that offense.”

However, Glencore is disputing the amount of restitution properly owed.

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Friday Roundup


Settled, not a victim, and monitor reports. It’s all here in the Friday roundup.


As highlighted in this prior post, in 2021 Shaquala Williams (a former employee of JPMorgan in New York city) filed a civil complaint in federal court (S.D.N.Y) against JPMorgan in connection with (at least in part) compliance obligations imposed upon JPMorgan in connection with resolution of its 2016 FCPA enforcement action. JPMorgan responded (see here) by filing a motion for summary judgment which was mostly denied by Judge Jed Rakoff who set a trial date for November 2022.

As reported here, the parties have reached an agreement to resolve the matter.

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Medical Services Company To File Restitution Claim In Connection With Glencore FCPA Enforcement Action


As highlighted here, in May 2022 Glencore (a commodities company incorporated in the United Kingdom and headquartered in Switzerland) resolved a net $443 million FCPA enforcement action.

According to the DOJ: “From at least in or about 2007 up to and including in or about 2018, Glencore, through certain of its employees and agents, while acting on behalf of Glencore, together with its co-conspirators, knowingly and willfully conspired and agreed with others to corruptly provide more than $100 million in payments and other things of value to various intermediaries with the intent that a significant portion of these payments would be used to pay bribes to and for the benefit of foreign officials to secure an improper advantage and to influence those foreign officials in order to obtain or retain business in Nigeria, Cameroon, Ivory Coast, Equatorial Guinea, Brazil, Venezuela, and the Democratic Republic of Congo.”

A portion of the conduct in the Democratic Republic of Congo related to bribe paid in connection with a litigation dispute.

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