A “Quick Guide” to Government Whistleblower and Voluntary Self-Disclosure Programs: Heed the Warning from DOJ to Strengthen Compliance Programs

April 15, 2024

The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to fortify their compliance programs. 

Recently, the DOJ unveiled plans for a groundbreaking whistleblower program, offering substantial monetary rewards to individuals who report corruption and corporate wrongdoing. This move, aimed at filling gaps in existing federal whistleblower programs, underscores the DOJ’s commitment to rooting out white-collar crime and corporate misconduct. 

The program represents the latest effort by the DOJ to incentivize whistleblowers to come forward with crucial information. Particularly targeted are criminal abuses within the U.S. financial system as well as Foreign Corruption Practice Act and Foreign Extortion Prevention Act violations. The message is clear: no corner of corporate malfeasance will be left unchecked. 

As corporations brace for enforcement, Deputy Attorney General Lisa Monaco has issued a stark warning: invest in compliance programs now or face the consequences later. The imperative is clear for chief compliance officers, general counsels, and attorneys to advise their clients to take proactive measures. 

But the DOJ’s new program is not the first. Several federal agencies have had successful whistleblower or self-disclosure programs for some time to encourage compliance and accountability. We’ve pulled together a quick guide of the major programs for reference. 

In anticipation of increased claims encouraged by the DOJ whistleblower program, corporations should evaluate and strengthen their compliance programs. From addressing internal complaints to risk assessment to policy implementation, our expertise can guide corporations through the intricate landscape of regulatory compliance.  

By investing in comprehensive compliance programs and embracing best practices, companies can navigate these turbulent waters with confidence and integrity. Now is the time to take action and safeguard against potential enforcement actions.