Companies will need to shore up their compliance practices—including the ease with which employees can report ethical lapses and wrongdoing internally—in the wake of the Justice Department’s announcement last week that it is launching a whistleblower program that could funnel millions of dollars to informants.
Corporate attorneys view the program, unveiled late last week by Deputy Attorney General Lisa Monaco at a white collar crime conference in San Francisco, as a significant new tool to combat a steady decline in DOJ prosecutions of white collar crime over the past decade. A report last year from the Transactional Records Access Clearinghouse at Syracuse University found that “the majority of criminal referrals for white-collar offenses that federal prosecutors receive are closed without prosecution.”