The DOJ recently created significant new incentives to encourage more individuals to self-report and to help the DOJ develop more corporate cases for prosecution. The new policies, however, may bring unintended consequences that could both complicate government enforcement efforts and hamper companies’ ability to self-police and remediate misconduct. In this guest article, Vinson & Elkins attorneys unpack the DOJ’s new whistleblower and non-prosecution agreement policies for self-reporting and identify areas of concern that corporate compliance officers will be forced to navigate in the evolving landscape. See “FCPA Enforcement, Changes in 2023 Foretell a Busy Year Ahead” (Jan. 17, 2024).