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Tuesday, August 19, 2025

DOJ Antitrust Division announces whistleblower rewards program - Nixon Peabody LLP

The United States Department of Justice’s Antitrust Division announced a potentially far-reaching whistleblower rewards program, which would, at the Antitrust Division’s discretion, provide for monetary awards to individuals who report criminal antitrust and certain other criminal violations and lead to a criminal fine of least $1 million. The program, set forth in a Memorandum of Understanding (MOU) between the Antitrust Division, the US Postal Service, and the Postal Service’s Office of Inspector General (USPIS) applies to covered criminal violations which USPIS “determines reasonably articulates a violation of law affecting the Postal Service, its revenues, or property.”

The press release and MOU do not specify what constitutes “affecting the Postal Service, its revenues, or property.” According to the MOU, although the Postal Service must suffer an “identifiable harm” from the violation reported, “the harm need not be material or otherwise pose any substantial detriment” to it. In its press release, the Antitrust Division states that the program will apply “across industries from healthcare to agriculture.” But whether the Antitrust Division and the Postal Service will take the position that any use of the mail in connection or furtherance of a covered violation is sufficient, or take a narrower view, is not yet known.

Key aspects of the whistleblower rewards program

Other key points include:

  • Only individuals are eligible for a reward. Under the MOU, although an...


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