The U.S. Attorney's Office for the Southern District of Florida has a new "Whistleblower Non-Prosecution Pilot Program":
The Whistleblower Program is designed to encourage voluntary self-disclosure by individual participants in certain types of non-violent criminal conduct involving corporations, to include financial crimes, corporate crimes, health care fraud, and public corruption.
In exchange for
self-disclosing, fully cooperating with authorities, and paying any applicable
victim compensation, restitution, or forfeiture, including returning any
ill-gotten gains, the U.S. Attorney’s Office for the Southern District of
Florida (USAO-SDFL) will enter into a non-prosecution agreement (NPA) where
certain specified conditions are met. One of those conditions is that the
government was not previously aware of the criminal conduct that is the subject
of the disclosure. The Whistleblower Program provides transparency
regarding the circumstances in which the USAO-SDFL prosecutors will offer NPAs
to incentivize individuals (and their counsel) to provide original and
actionable information. Incentivizing the disclosure of information will: (i)
help law enforcement investigate and prosecute criminal conduct that might
otherwise go undetected or be difficult to prove; and (ii) encourage companies
to create compliance programs that help prevent, detect, and remediate
misconduct.
1 comment:
Talk about bad timing. Harvey Shenberg must be shaking his head.
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