Why Are “Foreign Officials” Categorically Excluded From The DOJ’s Whistleblower Program?
This recent post highlighted the DOJ’s new Corporate Whistleblower Awards Pilot Program. (See here for 14 pages of guidance, and see here for the 4 page fact sheet).
To be eligible for an award, information provided by an individual must, among other things, “pertain” to four subject matter areas – one of which is “foreign corruption and bribery.”
The DOJ Guidance states:
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).
What Happened To The DOJ’s “90-Day Sprint”?
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.”
It is now 103 days later.
That’s it. That is today’s post.
DOJ’s New Whistleblower Pilot Program Aims to Generate Information About Corporate Wrongdoing, But Numerous Questions Remain
The following Covington attorneys contributed to this post: Steve Fagell, Nancy Kestenbaum, Aaron Lewis, Ashley Nyquist, Adam Studner, and Chas Hamilton.
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.”
Upcoming DOJ Whistleblower Program – How Will This Work?
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: