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A great speech from the U.S Deputy Attorney General Lisa Monaco providing an update the DoJs efforts to focus on white collar crime and its Whistleblower program.
Recognizing the success of Whistleblower programs run by Federal Agencies including the SEC and CFTC. The DoJ is planning a whistleblower rewards program that it will run. Launching a 90 day program to develop and implement a pilot program, with a formal start date later in 2024.
‘The premise is simple: if an individual helps DOJ discover significant corporate or financial misconduct  otherwise unknown to us  then the individual could qualify to receive a portion of the resulting forfeiture.’
In a specific reference the Deputy Attorney General puts compliance officers on notice that the DoJ will consider how well a companies compliance programs mitigate the companies most significant risks.
While her speech references AI (the latest buzz word to overtake crypto and NTFs), and wherever applicable, prosecutors will assess a company’s ability to manage AI-related risks as part of its overall compliance efforts. How will this impact cybersecurity? The SEC final rule is impacting 10-K and 8-K submissions, we are seeing individuals testifying to the SEC on the SolarWinds case and reading the recent unsealed case on Georgia Tech, members of the security team raised concerns on compliance to DFARS. Cyber is not just a significant risk, its a material risk. It is a risk that well documented as being poorly managed and a risk that increasing in frequency, complexity and severity of impact, that’s a function of compliance.
If the DoJ gets in on the ‘Whistleblower Act’ directly the game may change. No company can ignore the possibility for an employee reporting failure of corporate compliance and in turn governance.
@Thaddeus Dziekanowski Brian D. McCarthy Rachel V. Rose, JD, MBA
Veritas GRC
#cybersecurity #cyberriskmanagement #departmentofjustice
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