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Friday, August 15, 2025

DOJ Expands Whistleblower Program to Include Corporate Immigration Violations - JD Supra

The U.S. Department of Justice (DOJ) has expanded the Corporate Whistleblower Awards Pilot Program (CWAPP) to include corporate immigration violations, thereby incentivizing whistleblowers to report such violations.

What is the CWAPP?

Through the pilot program’s expansion, the DOJ expands its scrutiny to corporate compliance with federal immigration laws. The program was initially launched on August 1, 2024, as a three-year initiative aimed at prosecuting corporate crimes. This program was an effort by the DOJ to enhance its ability to combat corporate and white-collar crime with the help of whistleblowers. The four categories covered by the original program were:

  • Foreign corruption and bribery
  • Financial institution crimes
  • Domestic corporate corruption
  • Health care fraud involving private insurance plans

The program offers whistleblowers who provide original and truthful information about corporate misconduct 30% of the first $100 million in forfeited proceeds and up to 5% of amounts between $100 million and $500 million. On May 12, 2025, the DOJ expanded CWAPP to include corporate violations of federal immigration law through its White Collar Enforcement Plan, which will likely increase whistleblower reports.

Companies that disclose, cooperate, and implement appropriate remedies in their Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) within 120 days of the initial internal report will not be prosecuted by the DOJ. Employers frequently make errors when...



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