ABSTRACT
Compensating informants for their services is an inextricable component of our criminal justice system. The courts have accepted that it is sometimes necessary to compensate an informant before he will agree to undertake the often dangerous task of an undercover investigation. One judge explained, “Few would engage in a dangerous enterprise of this nature without assurance of substantial remuneration.”1 It is simply unreasonable to expect the government “to depend exclusively upon the virtuous in enforcing the law.”2
