Carrots and Sticks in Washington: Antitrust Whistleblowers and an FCPA SOL Extension

Mar 11, 2026

Washington signals are shifting: new antitrust whistleblower incentives and tougher individual prosecutions are changing corporate timelines. Lawmakers are pushing to extend the FCPA statute of limitations for past conduct. The discussion links enforcement pressure with incentives for self-reporting, culture, prompt investigations, and stronger compliance programs.

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INSIGHT

Compressed Timelines From Antitrust Whistleblowers

DOJ antitrust enforcement now compresses company timelines to investigate because whistleblowers and insiders can beat companies to prosecutors.
Daniel Glad warned whistleblower awards plus individual prosecutions create an "insider versus company" leniency race that shortens deliberation windows.

INSIGHT

FCPA Statute Extension As A Forward-Looking Enforcement Tool

Senate Democrats proposed the FCPA Reinforcement Act to extend FCPA statute of limitations from five to ten years for an eight-year window.
Sponsors like Elizabeth Warren framed it to let a future Democratic administration reach back at misconduct occurring now.

ADVICE

Act Now Because Future Enforcement Risk Is Real

Treat anti-corruption and antitrust compliance seriously now because political change could revive aggressive enforcement later.
Tom Fox and Matt Kelly urge compliance officers to use these Washington signals to push boards to strengthen programs today.

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The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look two recent developments sending a common message to compliance teams.

First, DOJ antitrust official Daniel Glad warns that a new Antitrust Whistleblower Awards program and increased pursuit of prison time for individuals compress companies’ timelines to investigate and self-disclose, because insiders may report first and cost those firms potential leniency. Second, Senate Democrats led by Elizabeth Warren propose the FCPA Reinforcement Act to extend the FCPA statute of limitations from five to 10 years for an eight-year window, aiming to preserve future enforcement capacity for misconduct occurring now. They connect these “sticks” with “carrots” such as fast declinations for self-disclosure, emphasizing the need for robust compliance programs, strong reporting culture, prompt investigations, and clear decisions on disclosure regardless of who controls Washington.

Key Highlights

· Two Washington Signals

· Antitrust Whistleblower Push

· FCPA Reinforcement Act

· Carrots Sticks and Culture

· Why Internal Reporting Matters

· Self Disclosure Through Line

Resources

Matt in Radical Compliance here and here

Tom

A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.

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