Additional Key Considerations
Voluntariness – Submissions to the program must be voluntary. They will not qualify if made after a government investigative inquiry made or as part of an existing obligation to report.
Truthfulness – Submissions must be made under the penalty of perjury. Submissions are not truthful and complete if the individual is involved but lies or conceals their conduct.
Cooperation – Participation in the program requires cooperation and testimony if asked.
Leading to Forfeiture – Information must lead to civil or criminal forfeiture in excess of $1,000,000 deposited into the Assets Forfeiture Fund.
DOJ Discretion – Awards by DOJ are discretionary and based on the net proceeds of the forfeiture. DOJ can also reduce or deny an award based on the whistleblower’s conduct, such as unreasonably delaying reporting, interfering with internal compliance mechanisms, participation in the misconduct, or having served in a management role over the conduct giving rise to the violation.
Confidentiality – DOJ will not publicly disclose information submitted to DOJ through the program that could reasonably be expected to reveal the identity of a whistleblower, except as required by law or Department policy as determined by the Department in its sole discretion, unless and until required to be disclosed to a defendant in connection with a judicial or administrative proceeding. The Department may provide your information to another federal, state, local, tribal, or international enforcement agency, provided that such agency complies with the same confidentiality commitments.
Anonymous Submissions – You may submit your information anonymously if you are represented by an attorney, but the Department of Justice reserves the right to require information regarding your identity at any time the Department deems it necessary to the prosecution of a case or to meet the Department’s legal obligations, policies, or procedures.
Other whistleblower programs – Individuals who would be eligible for an award through another U.S. government or statutory whistleblower, qui tam, or similar program had they reported the same original information to that other program will not be eligible for payment from the Corporate Whistleblower Awards Pilot Program