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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On March 7, 2024, the Department of Justice (DOJ) announced a new department-wide whistleblower pilot program. This program aims to incentivize whistleblowers to come forward with information related to corporate misconduct. By offering monetary rewards to whistleblowers, the program seeks to enhance enforcement efforts and promote transparency in the business world. Here’s what you need to know about the new program:

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The DOJ’s pilot program seeks to promote accountability in the criminal justice system by deterring abuses in the financial system, including accountability for corporate misconduct, stiffer penalties for corporate recidivists, and the use of “a mix of carrots and sticks to promote responsible corporate citizenship.” While existing whistleblower programs generally target fraud against the government or violations of securities rules and regulations, DOJ seeks to expand the scope of whistleblower programs to include corporate and individual misconduct related to bank fraud, corporate espionage, embezzlement, domestic corruption, and foreign corruption cases outside the jurisdiction of the SEC, including non-issuer Foreign Corrupt Practices Act cases and violations of the Foreign Extortion Prevention Act, which prohibits foreign government officials from demanding bribes.

Prior to the announcement of the new whistleblower program, DOJ’s enforcement activity has been consistent with its statements that it seeks to promote increased accountability, most notably in its convictions of the chief executive officers of FTX and Binance, two of the world’s largest cryptocurrency platforms, and its insistence that the Swedish company Ericsson, a corporate recidivist, plead guilty to FCPA violations following the revelations that it failed to disclose all evidence relating to a foreign bribery scheme that resulted in a 2019 deferred prosecution agreement.

The details of how the new whistleblower program will work have not yet been finalized, but already there are certain considerations of which corporate compliance officers and in-house counsel should take note:

In response to this new program, organizations should be assessing their own internal compliance procedures and investigatory protocols to make determinations about whether they should make changes to internal processes based on these new developments. As more details are announced about the new program, we will provide additional updates and commentary.

https://admin.thompsonhine.com/wp-content/uploads/2024/04/Thompson-Hine-Update-DOJs-New-Whistleblower-Rewards-Policy-A-Comprehensive-Overview.pdf

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<em>This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel.</em>

<em>This document may be considered attorney advertising in some jurisdictions.</em>

The DOJ’s New Whistleblower Rewards Policy: A Comprehensive Overview

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