LIEB BLOG

Legal Analysts

Wednesday, August 07, 2024

DOJ's Corporate Enforcement and Voluntary Self-Disclosure Policy

DOJ just launched the Corporate Whistleblower Awards Pilot Program to reveal and prosecute corporate crime. 


Companies should take advantage of Self-Disclosure to earn a presumption of a declination – avoidance of prosecution – by voluntarily notifying the DOJ of corporate misconduct initially reported to them by internal whistleblowers.


In order to qualify for a declination under the DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy, companies must self-report the business’s misbehavior unearthed internally within 120 days of that whistleblower report. Additionally, the company self-reporting must occur prior to the agency contacting them and the company must pay out the amount that would be forfeited, unlawfully obtained funds, as well as any victim compensation payments stemming from the corporate misconduct.


All employers should immediately update their internal policies to motivate corporate self-reporting and internal whistleblowing by workers.