News
Goldberg Kohn White Collar Defense Principal Charles “Chip” Mulaney is quoted in “Racing Against Whistleblowers Could Cost Companies,” published in the Nov. 5, 2026, edition of Law360. The article concerns the U.S. Department of Justice’s new Whistleblower Incentive Program (WHIP) and the challenges it may create for companies investigating and responding to potential misconduct.
The program offers whistleblowers rewards ranging from $10,000 to $30,000 when their tips lead to criminal charges in certain fraud cases involving healthcare and government programs and benefits. According to Chip, the initiative could increase the pressure on companies to investigate potential misconduct and make decisions about voluntary self-disclosure before a whistleblower reports the issue to the government.
“The time pressure on a company is certainly increasing,” says Chip in the article. “We’re already seeing an uptick in whistleblowers coming forward with reports of misconduct, and I think it’s only going to increase.”
As leader of Goldberg Kohn's white-collar defense and investigations practice, Chip defends companies and individuals facing criminal exposure, civil litigation and parallel enforcement actions. Chip also conducts confidential and independent internal investigations into allegations of financial misconduct, regulatory breaches, harassment, discrimination and ethics violations.
In the article, Chip also highlighted the difficult balance companies face between moving quickly and conducting a sufficiently thorough internal investigation. Corporate investigations can require reviews of emails, text messages, contracts and financial records, as well as employee interviews. Moving too quickly can leave a company without a complete understanding of the conduct it is reporting.
Chip further noted the uncertainty surrounding the DOJ’s expectations for the timing of internal investigations, including “how the DOJ views a reasonable time for an internal investigation versus what the company views as reasonable.”
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