In 2023, Connecticut-based Freepoint Commodities LLC (Freepoint) entered into settlement agreements with a number of enforcers stemming from an alleged conspiracy to bribe a state-owned company in South America. As part of the settlements, Freepoint agreed to enhance its corporate governance and compliance program, and to report any subsequent issues to the DOJ. However, in May 2025 a former employee filed a whistleblower suit alleging insider trading violations and retaliation. The implications for companies, like Freepoint, that are bound by deferred prosecution agreements or other settlement agreements could be quite significant. In this guest article, Luke Cass, Audrey Karman and Ian O’Keefe of Womble Bond Dickinson discuss the various programs meant to encourage whistleblowing, how whistleblowers pose risks to existing DOJ resolutions and how compliance programs can help mitigate those risks. See “Obligations Linger Despite Freepoint’s Settlements With DOJ and CFTC” (Aug. 28, 2024).