As you may know, certificate holders (e.g. Part 121, 135 and 145, to name a few) can take advantage of the the Voluntary Disclosure Reporting Program (“VDRP”) to avoid enforcement action when a qualifying regulatory violation has occurred. However, what about an employee of the certificate holder? Well, according to a D.C. Circuit Court of Appeals decision, such employees may prove compliance with the VDRP to avoid civil penalties or other sanctions in an enforcement action. For an analysis of the court decision, please read my article on the subject here.