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Daniel Patrick Wendt Comments on Whistleblower Rewards Pilot Program in Law360

Subtitle
"DOJ Whistleblower Pilot on Deck as Cos. Boost Compliance"

Law360

In this article, Daniel Patrick Wendt discussed the incentives and FCPA enforcement priorities of the Department of Justice (DOJ), noting the DOJ's prioritization of companies who are willing to implement changes at the senior level when assessing cooperation credits. "I think the cases where companies really get hammered are when the companies are willing to admit fault, but only to a point, and are not willing to change certain leadership," Wendt said. To handle investigations and remediation as well as possible, he also recommended that companies "prioritize establishing as much infrastructure and policy-level approaches for handling disclosure decisions as they can, prior to a real crisis.