A whistleblower awards program launched by the U.S. Department of Justice Aug. 1 creates a new dilemma where companies may face prosecution if they fail to self-report corporate wrongdoing to the feds before individual whistleblowers come forward, according to Big Law white-collar criminal defense experts.

The DOJ’s Corporate Whistleblower Awards Pilot Program is “very similar” in style and structure to the U.S. Securities and Exchange Commission’s whistleblower program created by Section 922 of the 2010 Dodd-Frank Act, according to Arnold & Porter Kaye Scholer partner Jane Norberg, a former SEC whistleblower chief who advises clients on sensitive whistleblower matters.