2024 in Review: Policy Changes Seek to Shift the Self-Reporting Calculus

With the introduction of several DOJ programs aimed at providing rewards to those who bring information to prosecutors, 2024 was a strong year for whistleblowers. This second article in a series examining developments in 2024 discusses how the new programs are doing and what to expect from them going forward. We incorporate insights shared with the Anti-Corruption Report by defense counsel from multiple firms, as well as those expressed by government enforcers at the American Conference Institute’s International Conference on the FCPA held in December 2024. The first article looked at the role international cooperation continues to play in FCPA enforcement. See “The Price Is Right? How DOJ’s New Whistleblower and NPA Policies Could Bring Unexpected Costs” (Jun. 19, 2024).

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