Manatt Trial, White Collar and Investigations Partner Randy Grossman was quoted in Anti-Corruption Report on the DOJ’s recently launched Corporate Whistleblower Awards Pilot Program (WAPP).
Under this program, whistleblowers, even culpable individuals minimally involved, can be eligible for an award when providing new information to the DOJ about known wrongdoings. Despite the possibility of winning an award, those involved in the wrongdoing may hesitate to report. If found ineligible for an award, the DOJ will assess whether the culpable individual is eligible for a non-prosecution agreement under DOJ’s Pilot Program on Voluntary Self-Disclosures for Individuals (VSD Program). But if the whistleblower also fails to qualify for the VSD Program, it is unclear what should happen next. “In other words, without knowing more about how DOJ will view the unique circumstances surrounding a self-disclosure made under this program, a ‘culpable’ individual seeking a carrot could end up with a stick,” Grossman said.
Anti-Corruption Report subscribers can read the full article here.