DOJ Pilot Program Encourages Voluntary Self-Disclosure of Corporate Criminal Actions

According to an article by BCLP, the U.S. Department of Justice (DOJ) has introduced a pilot program to encourage individuals to voluntarily disclose their involvement in certain types of criminal conduct related to corporations. Under this program, individuals who meet specific criteria can receive a mandatory non-prosecution agreement (NPA), effectively avoiding prosecution. The DOJ pilot program aims to increase the reporting of corporate crimes and incentivize companies to establish and reinforce compliance programs.

The criteria for eligibility include making a voluntary disclosure to the DOJ, providing original information on specific types of crimes such as financial fraud or corruption, cooperating fully with the DOJ’s investigation, and meeting certain eligibility requirements, such as not being involved in violent crimes or holding certain positions within the company.

This program formalizes a practice that the DOJ has occasionally employed but rarely implemented—allowing individuals involved in corporate wrongdoing to avoid convictions altogether by voluntarily disclosing their involvement. The initiative is expected to lead to a rise in reports of corporate crime to the DOJ.

This initiative follows the DOJ’s earlier announcement of plans to offer whistleblower awards to individuals who disclose corporate misconduct voluntarily. The DOJ’s efforts underscore a strong push to compel companies to adhere to legal standards.