The stakes for non-compliance with federal immigration law have just increased exponentially. On May 12, 2025, the U.S. Department of Justice’s Criminal Division unveiled its new White Collar Enforcement Plan (“Enforcement Plan”) titled, “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime.” The Enforcement Plan amended the Division’s Corporate Whistleblower Awards Pilot Program (CWAPP) to include “violations by corporations of federal immigration law.”
CWAPP came into existence during the Biden administration in 2024. CWAPP identified a targeted list of white-collar crimes that included bribery, money laundering, and health care fraud. The program encouraged individuals with knowledge of such criminal conduct to come forward by offering financial incentives if they provided information that enabled the DOJ to identify illegal activity and seize corporate assets derived from the offense.
The newly unveiled Enforcement Plan amends CWAPP to reflect “priority areas of focus.” One of those areas of focus is “violations by corporations of federal immigration law.” This is a significant expansion of liability risk for employers. Whistleblowers, including current and former employees who may be disgruntled, can now file a tip with the DOJ regarding immigration non-compliance and potentially recover a substantial bounty award should the DOJ obtain a successful prosecution.
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