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New DOJ Self-Disclosure Pilot Program Increases Risk for Startups
The Department of Justice (DOJ) has created new incentives for employee, or anyone, to report criminal misconduct allegedly committed by companies and their agents. Given their often laxer internal reporting structures and higher employee turnover rates, startup companies should pay particularly close attention to this new DOJ development to best mitigate legal risks.
On April 15, 2024, the DOJ's Criminal Division announced a new program that awards non-prosecution agreements (NPAs) to individuals who "voluntarily self-disclose[] original information about criminal misconduct." This new program, the Pilot Program on Voluntary Self-Disclosures for Individuals, establishes a unique incentive structure that encourages the reporting of corporate misconduct and promotes corporate compliance.
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