7 Strategies to Comply with the DOJ’s New Whistleblower Rewards Program

Woods Rogers’ Justin Lugar and Mike Gill, Assistant General Counsel and Director of Investigations at HII, authored an overview for the Association of Corporate Counsel’s ACC Docket discussing the Department of Justice’s ramped-up enforcement actions under the Biden Administration. The article addresses these recent policies and directives, highlighting the intersection of internal compliance programs, corporate self-disclosure policies, and the new Whistleblower Rewards Program. It also addresses the importance of internal reporting, challenges encountered in corporate operations, and considerations for effectively implementing these policies in corporate settings.

While DOJ’s new Whistleblower Rewards Program has been billed as a ‘pilot’ program, there is little reason to believe that DOJ will scrap the program, particularly where the return on investment of whistleblower programs far exceeds the cost,” the authors write. “There are undoubtedly foreseeable wrinkles that DOJ will have to iron out but taking proactive steps to craft a gameplan and playbook, as well as internal assessments of compliance culture and reporting, will mitigate the risk of a new, untested program. Companies should consider this new emphasis on whistleblowing by DOJ as an opportunity to tighten controls, enhance internal reporting and communication, and reinforce a strong compliance culture.”

Read the complete article in the ACC Docket’s September issue, available here.