Investigations, Enforcement, & Compliance Alerts

Given the recent changes the Trump Administration has made at the Department of Justice (DOJ),many people have wondered when a formal change to the DOJ’s white-collar prosecution policies, particularly the corporate self-disclosure policy, might come. During remarks at a Financial Crimes Conference on May 12, Matthew Galeotti, the new Head of the DOJ’s Criminal Division, announced some of the changes to the DOJ’s policies, starting with the new commitment to be less “heavy-handed with the stick, and [less] stingy with the carrot.”  

The Department of Justice has formally launched a three-year pilot of its Corporate Whistleblower Awards Program (Pilot Program), which is likely to increase the number of government investigations of corporate wrongdoing—and related recoveries—in key areas over the course of the next several years. Under the Pilot Program, whistleblowers who provide DOJ’s Criminal Division with truthful information about corporate misconduct may be eligible for significant monetary awards.  In back-to-back statements, Deputy Attorney General Lisa Monaco and Principial Deputy Assistant Attorney Nicole Argentieri announced the launch of the Pilot Program and filled in some of the blanks from prior announcements about the Pilot Program.

The Department of Justice is intensifying its corporate enforcement efforts with a new whistleblower program. DOJ has made it clear that corporations and individuals with knowledge of corporate misconduct should “come see us before we come see you.”