Credit: freshidea/Adobe Stock DOJ Seeks to Incentivize Corporate Compliance Through Voluntary Self-Disclosure Programs, Including Program for Individuals
The DOJ and certain individual U.S. Attorney's Offices have announced six different voluntary self-disclosure or whistleblower policies and programs. With the proclamation of each one, the DOJ sent a clear message that they remain focused on corporate enforcement and want to incentivize companies and corporate insiders to self-report corporate malfeasance.
July 05, 2024 at 10:00 AM
6 minute read
In the span of 15 months, the U.S. Department of Justice (DOJ) and certain individual U.S. Attorney's Offices announced no less than six different voluntary self-disclosure or whistleblower policies and programs. See, e.g., Justice Manual § 9-47.120; Monaco, Lisa, "Policy Designed to Encourage Disclosure of Misconduct and Hold Individual Wrongdoers Accountable" (DOJ, Oct. 4, 2023); Press Release, "Policy Sets National Standard for Circumstances Under Which Companies May Receive Credit for Voluntarily Self-Disclosing Criminal Conduct, and Benefits of Self-Disclosure" (DOJ, Feb. 22, 2023).
With the proclamation of each policy or program, the DOJ and its component offices sent a clear message that they remain focused on corporate enforcement and want to incentivize companies and corporate insiders to self-report corporate malfeasance. Indeed, the message to companies is "[i]nvest in compliance now or your company may pay the price—a significant price—later." Monaco, Lisa, "Policy Designed to Encourage Disclosure of Misconduct and Hold Individual Wrongdoers Accountable" (DOJ, Oct. 4, 2023)
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