DOJ Is Serious About New Criminal Whistleblower Programs Involving Fraud and Antitrust

Key Takeaways 

• DOJ is “all-in” on whistleblowers, with new DOJ Criminal Division and Antitrust Division programs expecting companies to detect issues, remediate, and promptly self‑report potential crimes.
• The Antitrust Division’s first-ever whistleblower award signals an expansive approach where any antitrust offense involving the mail may qualify for whistleblower awards.
• Companies should urgently reassess compliance programs for early detection, rapid escalation, credible remediation, and alignment with DOJ’s 2024 compliance evaluation guidelines. 

The U.S. Department of Justice (DOJ) is signaling—through recent whistleblower programs announced by the Criminal Division and the Antitrust Division—that it is “all-in” on whistleblowers and expects companies to detect, remediate, and, where appropriate, promptly self-report potential criminal violations. The Antitrust Division has now issued its first-ever whistleblower reward in a criminal antitrust matter involving the U.S. Postal Service (USPS). The award signals DOJ’s expansive view of the use of whistleblowers in criminal contexts, including for antitrust violations. In fact, while the Antitrust Division’s new whistleblower rewards program is supposedly limited to claims affecting USPS, awards may be available to whistleblowers that report any antitrust offense involving the mail. 

These developments increase the risk of whistleblowers reporting alleged criminal misconduct directly to DOJ. As DOJ has noted in a recent press release, “employees and their attorneys are incentivized to blow the whistle and beat their companies to the Division’s doorstep.” To minimize that risk, companies should evaluate or reevaluate their compliance programs with a focus on early detection, rapid escalation, and credible remediation. 

DOJ Has Announced Two Whistleblower Programs 

On May 12, 2025, the Criminal Division announced the Corporate Whistleblower Awards Pilot Program for reporting “corporate misconduct that results in a successful forfeiture.” On July 8, 2025, the Antitrust Division announced a whistleblower program for reporting criminal antitrust “violations of law affecting the Postal service, its revenues, or property.” When announced, there was some uncertainty about DOJ leadership’s commitment to the whistleblower programs and, in practice, how often awards would be paid to whistleblowers. 

The First Whistleblower Award 

Less than one year after announcing the new whistleblower programs, DOJ announced its first whistleblower award through one of those programs. Specifically, on January 29, 2026, the Antitrust Division announced that it had awarded $1 million to a whistleblower whose information led to a deferred prosecution agreement with EBLOCK Corporation, which agreed to pay a $3.28 million criminal fine and undertake remedial measures. The conduct involved bid rigging on an online used-vehicle auction platform, including misuse of confidential bidding information, software-enabled fake bids, and profit sharing among co‑conspirators.  

This whistleblower award is notable because it signals a very expansive application of the Antitrust Division’s whistleblower award program: Any antitrust offense involving the mail may be eligible. By its terms, the program applies when the violations of law “affect[] the Postal Service, its revenues, or property.”  Here, the offensive did not target USPS, USPS was not a victim, and arguably USPS’s operations, revenues, and property were not materially affected. Unlike the 2007 guilty plea involving an antitrust offense where auctions held by the USPS were rigged, this recent award involved an offense where “the defendant used the U.S. Mail to send documentation related to the scheme.” In DOJ’s press release, the chief postal inspector articulated a much broader standard for the types of violations that qualify for whistleblower awards: “antitrust and related competition crimes with a connection to the U.S. Mail” (emphasis added). The application of the program to anything with a “connection” to U.S. mail greatly expands the number of antitrust violations potentially eligible for a whistleblower award. 

What This Means for Companies 

In light of these developments, companies should work closely with experienced legal counsel to evaluate or reevaluate their compliance programs with a focus on the Antitrust Division’s 2024 Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations guidelines and the Criminal Division’s 2024 Evaluation of Corporate Compliance Programs guidelines. This evaluation includes reviewing whistleblower policies and trainings, M&A due diligence questionnaires, channels for reporting potential violations, monitoring and auditing to detect potential violations, antiretaliation protections, and investigation protocols to ensure companies can investigate and meet the self‑reporting window, if needed.