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Key Takeaways

  1. The DOJ will continue to hold culpable individuals accountable for financial misconduct and will pursue significant penalties for corporate recidivists.
  2. The DOJ is developing and implementing “carrots and sticks” that promote a “first-in-the-door” strategy to encourage companies and individuals to report significant financial misconduct, rather than sit on evidence of wrongdoing.
  3. Over the next 90 days, the DOJ will develop a new whistleblower program that will allow an individual to retain a portion of a civil or criminal forfeiture recovery, if the whistleblower provides information about financial misconduct that was previously unknown to the government.

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