On 8 July 2025, the US Department of Justice Antitrust Division (the Division) unveiled a new Whistleblower Rewards Program (the Whistleblower Program) that provides a significant monetary incentive—up to 30% of the recovered criminal fine—to individuals who voluntarily provide the Division with original information about criminal antitrust violations. A first-of-its-kind in US antitrust enforcement (although numerous foreign jurisdictions have similar programs in place), the Whistleblower Program seeks “to create a new pipeline of leads,” according to Division Assistant Attorney General Abigail Slater, and could accelerate the race to leniency for companies under the Division’s long-standing Corporate Leniency Policy.
While time will tell the full scope and impact of the Whistleblower Program, including how certain provisions and potentially impactful limitations will be applied, the rollout of the Whistleblower Program itself should serve as another reminder to companies of the importance of antitrust compliance and a good reason to refresh internal reporting policies and procedures. Below, we take a closer look at the Whistleblower Program, including its authority, formation, and operation; explain who may and may not be eligible for an award and how the award amount is determined; provide some predictions on its impact on the Division’s Corporate Leniency Policy; and provide practical takeaways for companies and their leadership teams to mitigate risk.
HARRISBURG, PA — The plaintiffs’ bar is working overtime to convince the Pennsylvania General Assembly to pass a state False Claims Act (FCA), arguing that it will raise revenue to help close the ...