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Voluntary Disclosure Compliance White Collar Crimes

Foley & Lardner LLP

A Review of Recent Whistleblower Developments – Q3 2024

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On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more

The Volkov Law Group

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

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The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws.  Companies have to weigh carefully the risks when...more

Alston & Bird

Getting on the Bandwagon: Eight Additional U.S. Attorneys’ Offices Announce Corporate Whistleblower Pilot Programs

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Our White Collar, Government & Internal Investigations Team examines a plethora of new whistleblower pilot programs from federal prosecutors across the country....more

Fenwick & West LLP

DOJ ‘Upping the Ante’ for Corporate Self-Disclosure with New Corporate Whistleblower Awards Pilot Program

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Earlier in 2024, DOJ’s Criminal Division announced a new Corporate Whistleblower Awards Pilot Program granting whistleblower awards to individuals who provide information in four priority areas. ...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

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DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

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In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

Farella Braun + Martel LLP

New DOJ Corporate Whistleblower Awards Program Pits Company Compliance Programs Against the Clock

The Department of Justice announced a Corporate Whistleblower Awards Pilot Program on August 1, 2024. If a whistleblower voluntarily reports original, truthful, and complete information to DOJ in a relevant subject...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

BakerHostetler

DOJ Corporate Whistleblower Awards Pilot Program

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DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more

K&L Gates LLP

Department of Justice Launches First-Of-Its-Kind Corporate Whistleblower Awards Program

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After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....more

Womble Bond Dickinson

DOJ Debuts Pilot Corporate Whistleblower Awards Program

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The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more

Dorsey & Whitney LLP

DOJ’s New Whistleblower Program Incentivizes Individuals and Corporations to Disclose Wrongdoing

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The U.S. Department of Justice (DOJ) just launched the new corporate whistleblower awards pilot program that it previewed this past March. ...more

Latham & Watkins LLP

DOJ Launches New Whistleblower Incentive Program

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DOJ’s pilot program aims to fill gaps in existing federal whistleblower programs and incentivize prompt corporate self-disclosure alongside individual whistleblower tips. Following the March 2024 announcement of its...more

Alston & Bird

“No One Wants to Be Second”: The DOJ’s New Corporate Whistleblower Awards Pilot Program

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The DOJ’s much-anticipated corporate whistleblower program is here, making multimillion-dollar financial awards available to eligible individuals who report corporate misconduct. There’s lots in it to digest, and our White...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Epiq

Compliance Programs Under Scrutiny

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In today’s regulatory environment, corporations have a heightened obligation to investigate potential wrongdoing by their employees and to monitor, and possibly disclose, incidents of illegal conduct....more

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

McCarter & English, LLP

DOJ Launches Pilot Program to Encourage Reporting of Criminal Activity

The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...more

Lowenstein Sandler LLP

DOJ Says You Can Put the Fire Out From Inside the House: New Voluntary Self-Disclosure Program Seeks to Root Out Corporate Crime...

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Introduction: On April 15, 2024, the Department of Justice’s (DOJ) Criminal Division announced a new Pilot Program on Voluntary Self-Disclosure for Individuals. Under this program, individuals who voluntarily disclose certain...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

Bradley Arant Boult Cummings LLP

Criminal Division’s new voluntary self-disclosure program still uncertain and risky

On April 15, 2024, the Department of Justice released its “Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals.” Similar in many ways to programs introduced earlier this year by the U.S. Attorney’s...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

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On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

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Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

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