Highlights
- Whistleblower Rewards Now Apply to Immigration Violations: Employees may receive financial incentives for reporting corporate immigration law breaches directly to the Department of Justice (DOJ).
- Path to Avoid Prosecution: The DOJ will not prosecute immigration violations if companies promptly investigate, disclose and implement appropriate remediation.
- Investment in Compliance is Paramount: A strong internal compliance and reporting system can help mitigate legal and reputational risks.
As immigration detentions and deportations rise nationwide, the DOJ is expanding its scrutiny to corporate compliance with federal immigration laws.
Initially launched under the prior administration, the DOJ’s Corporate Whistleblower Awards Pilot Program (CWAPP) targets white-collar offenses such as healthcare fraud, money laundering and bribery of foreign officials. CWAPP offers whistleblowers up to 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 through its White-Collar Enforcement Plan to include corporate violations of federal immigration law — reflecting the current administration’s enforcement policy. This expansion is likely to increase whistleblower reports, investigations and DOJ enforcement activity.
Notably, the DOJ recently announced that it would not prosecute companies that quickly disclose, cooperate and implement appropriate remediation as part of its...
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