In a significant shift in enforcement strategy, the U.S. Department of Justice (DOJ) has expanded its Corporate Whistleblower Awards Pilot Program (CWAPP) to include violations of federal immigration law. This move reflects a broader governmental push to hold corporations accountable for immigration-related misconduct and incentivize insiders to report violations — particularly those involving employment-based visa programs such as the H-1B. Therefore, all employers of non-citizens should understand their legal obligations and limit their exposure.
Originally launched in August 2024 under the Biden administration to combat white-collar crimes such as bribery and fraud, CWAPP was expanded in May 2025 by the Trump administration to include immigration violations. Under the updated program, whistleblowers can receive up to 30% of any monetary recovery resulting from their tips, provided the case leads to a forfeiture of at least $1 million. Awards are also available to whistleblowers who report federal immigration violations that result in forfeitures at lower thresholds.
Historically, whistleblowers attempted to use the False Claims Act (FCA) to pursue visa fraud cases, but courts have generally rejected these claims. Now, the DOJ is relying on criminal statutes to prosecute immigration-related misconduct. The expansion specifically targets the following violations:
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