Could your firm potentially be the subject of a DOJ whistleblower action? Time to get ready

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Now that the U.S. Department of Justice (DOJ) launched a new pilot whistleblower program, many questions remain. What types of companies might find themselves to be the subject of a criminal investigation stemming from a whistleblower tip? And what should they do to prepare for a whistleblower tip?

The answers, according to Patrick Gushue, acting director of the DOJ’s Corporate Whistleblower Awards Pilot Program, are privately held companies, private insurers, foreign-based companies, cryptocurrency platforms, and issuers; domestic and foreign-based banks and financial institutions, including credit unions; and nonprofit organizations.

A big reason the DOJ launched its pilot whistleblower program, Gushue said, was to encourage these entities to invest in their compliance functions.

“We wanted to incentivize companies to improve their compliance functions, to invest in compliance, to take corrective steps to investigate wrongdoing, and to report misconduct to the department,” Gushue said in a Compliance Week webcast Thursday, sponsored by Resolver.

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