July 29, 2025

DOJ Antitrust Division Launches Whistleblower Rewards Program

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Key Takeaways

  • The US Department of Justice (DOJ) Antitrust Division has launched its first-ever Whistleblower Rewards Program, offering financial incentives to individuals who report criminal antitrust violations affecting the US Postal Service (USPS).
  • Whistleblowers may receive 15%–30% of criminal fines or recoveries exceeding $1 million, depending on the value and impact of their information.
  • The program is expected to increase detection and enforcement of antitrust crimes, particularly those that are difficult to uncover through traditional means.
  • The initiative operates alongside the Division’s Corporate Leniency Policy and aligns with the DOJ’s broader whistleblower efforts, including the Criminal Division’s pilot program, and broader DOJ efforts to incentivize whistleblowing across federal enforcement areas.

Overview of the New Whistleblower Rewards Program

On July 8, 2025, the DOJ Antitrust Division, in partnership with the USPS and its Office of Inspector General, announced the launch of a Whistleblower Rewards Program, aimed primarily at uncovering criminal antitrust violations that harm consumers, taxpayers, and free market competition. All three agencies are members of the Antitrust Division’s Procurement Collusion Strike Force, and entered into a memorandum of understanding (MOU) which outlines the policies and procedures in the formation and operation of the Whistleblower Rewards Program.

This marks a significant shift in the Division’s approach to uncovering and prosecuting antitrust crimes, as it is the first time the Division is offering direct financial rewards to individual whistleblowers. The program is designed to incentivize individuals to come forward with original, non-public information about criminal antitrust violations (such as price fixing, bid rigging, and market allocation schemes) that result in harm to the USPS, its revenues, or its property and which lead to criminal fines or recoveries of at least $1 million.

The program arises out of statutory authority (39 U.S.C. §§ 2601 and 404(a)(7)) that allows the USPS to collect fines and penalties for violations affecting its operations and to pay a portion to those who inform the agency about such violations. The DOJ’s stated goal is to “break down [the] walls of secrecy” that often surround antitrust crimes, which are typically difficult to detect without insider information. The initiative is part of a broader DOJ push to incentivize reporting of corporate misconduct, building on recent pilot programs offering non-prosecution agreements and monetary awards for whistleblowers in other contexts.

Eligibility and Scope

To be eligible for a reward, a whistleblower must voluntarily provide original, specific, and credible information about a criminal antitrust violation that affects the USPS. The information must lead to a criminal fine or recovery of at least $1 million. The program covers criminal violations of the Sherman Act (including price fixing, bid rigging, market allocation, and certain monopolization cases) as well as federal crimes committed to effectuate, facilitate, or conceal Sherman Act violations, and crimes targeting or affecting public procurement or the conduct of federal competition investigations.

Notably, the MOU notes that harm to the USPS need not be “material of significant;” any identifiable impact may suffice. This broadens the potential reach of the program to a wide range of industries and conduct.

Certain individuals are excluded from eligibility, including those who were the leader or originator of the illegal conduct, those who coerced others to participate, and current law enforcement employees or their close relatives. The program also contains specific provisions regarding compliance personnel and internal auditors: while information learned in these roles is generally not considered “original,” there is a carve-out if the individual reports internally and then to the DOJ within 120 days.

Reward Structure and Process

If the information provided by a whistleblower results in a successful criminal prosecution and a fine or recovery of at least $1 million, the whistleblower may receive between 15% and 30% of the amount collected. The precise award is determined at the sole discretion of the Antitrust Division, in consultation with the USPS and its Office of Inspector General, and is based on factors such as the value and reliability of the information, the whistleblower’s cooperation, and any hardships faced as a result of reporting. Multiple whistleblowers may share a single award.

The process for submitting a report is straightforward: individuals may submit information directly to the Antitrust Division, the USPS Office of Inspector General, or the US Postal Inspection Service. The agencies will evaluate whether the information is original, specific, and credible, and whether it meets the program’s eligibility criteria.

Interaction with the Corporate Leniency Policy

The Whistleblower Rewards Program operates in parallel with the Antitrust Division’s longstanding Corporate Leniency Policy, which provides non-prosecution protections to the first company or individual to self-report and cooperate in a criminal antitrust investigation. The introduction of financial rewards for individual whistleblowers is expected to accelerate the “race to report,” increasing the risk that employees or other insiders will bypass internal reporting channels in favor of direct disclosure to the DOJ.

This dynamic raises the stakes for companies, potentially narrowing the window for securing leniency and increasing the risk of enforcement actions based on whistleblower tips. Companies must be prepared for the possibility that employees, compliance personnel, or others with first-hand knowledge may report potential violations directly to the government, especially if internal reporting mechanisms are perceived as ineffective or retaliatory.

Implications for Corporate Compliance

The launch of the Whistleblower Rewards Program mirrors the approach of some other enforcers around the world and underscores the DOJ’s commitment to expanding its enforcement toolkit and increasing the detection of antitrust crimes. Companies should take proactive steps to mitigate risk. This includes: (i) strengthening training and awareness across all levels of the organization; (ii) reviewing and strengthening antitrust compliance programs; (iii) ensuring that internal reporting systems are accessible, confidential, and free from retaliation; and (iv) promptly investigating and addressing internal reports of potential antitrust (and other) violations. Companies should also consider the potential for whistleblower disclosures when evaluating whether to seek leniency or self-report to the DOJ.

Virtually all companies doing business in the United States use the US mails or otherwise interact with the USPS, so the new program is likely to reach every industry. Further, the program may serve as a model for broader whistleblower initiatives in the future. The DOJ Antitrust Division press release announcing the Whistleblower Rewards Program specifically calls out the healthcare and agricultural industries, and these sectors in particular are likely to face particular scrutiny.

Looking Ahead

The Antitrust Division’s Whistleblower Rewards Program is expected to increase the volume and quality of leads regarding antitrust violations. The Program signals a growing emphasis on incentivizing insider disclosures and may pave the way for expanded whistleblower protections and rewards in the future.

If you have questions about the new Antitrust Division Whistleblower Rewards Program, its implications for your business, or best practices for compliance and internal reporting, please contact your usual Mayer Brown contact or a member of our Antitrust & Competition or White Collar Defense & Investigations teams.

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