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Antitrust Division Launches Whistleblower Rewards Program

Client Alert | 4 min read | 07.11.25

On July 8, 2025, the Department of Justice Antitrust Division announced a new program to provide rewards to individuals who report antitrust violations related to the Postal Service. This is the first program of its kind to provide a monetary reward to individuals who assist in the prosecutions of antitrust crimes. Under the new initiative, whistleblowers will have the opportunity to receive up to 30% of any criminal fines recovered for violations affecting the Postal Service, its revenues, or its property. 

The Division said that the whistleblower program will incentivize individuals to report “specific, credible and timely information” about illegal agreements and create a pipeline of leads from people with firsthand knowledge of criminal antitrust offenses and will help the Division “break down those walls of secrecy and hold violators accountable.”

Historically, the Division principally relied upon its leniency program to incentivize reporting of wrongdoing by those involved in criminal antitrust offenses. This new program expands upon those efforts to identify and prosecute collusion by targeting whistleblowers rather than those individuals who participated in potentially unlawful conduct. However, unlike the leniency program, individuals who report wrongdoing through the whistleblower hotline will not have any of the protections and benefits of leniency.

Key Parameters: not all information or individuals will qualify for an award

As part of the new program, whistleblowers who voluntarily report original information about antitrust and related offenses affecting the Postal Service that result in criminal fines or recoveries of at least $1 million could be eligible for an award between 15-30% of the recovery, with payment made at the discretion of the Division.

In its Memorandum of Understanding with the Postal Service and Postal Service Office of Inspector General, the Division provides several constraints on what will be considered original information:

  • It must be derived from the individual’s independent knowledge;
  • It must not be previously known to the Division or Postal Service from another source; and
  • It must not be derived exclusively from a judicial or administrative hearing, government report, audit, or investigation, unless the whistleblower is the source of that information.

Notably, information will not be considered original if the person was an officer, director, trustee, or partner and learned of the information from another person. 

In addition, to be eligible for an award, the Division will consider whether the whistleblower “provided ongoing, extensive, and timely cooperation and assistance” to the investigation. The Division will also consider the following factors:

  • Whether the information was directly related to a successful prosecution;
  • Whether the information supported a criminal conviction; or
  • Whether the information provided resulted in the conservation of government resources.

The Division will similarly consider whether the whistleblower participated in the criminal conduct reported, received an award from another government agency or civil suit, or conversely, faced any “unique hardships” due to whistleblowing.   

Antitrust Division continues its collaboration with other agencies

The announcement deepens the collaboration between the Division and the Postal Service in bringing criminal antitrust enforcement actions. The Postal Service Office of Inspector General was one of the original members of the Procurement Collusion Strike Force (“PCSF”), which the Division launched in November 2019, aiming to deter and prevent collusive behavior and to detect, investigate, and prosecute efforts to rig bids, fix prices, and allocate bids.

The scope of the whistleblower program is potentially narrow, as it only pertains to criminal antitrust violations affecting the Postal Service, its revenues, or its property. However, enforcement priorities may be gleaned from the PCSF’s previous enforcement actions which have largely focused on rooting out bid-rigging, fraud, and other criminal antitrust schemes in public contracts and projects.

Whistleblowers remain central to DOJ’s enforcement efforts

Furthermore, the program reinforces the current administration’s interest in bringing enforcement actions initiated by whistleblowers. In August 2024, DOJ announced a Corporate Whistleblower Awards Pilot Program, which was expanded in May, 2025 as part of DOJ’s Reprioritization of Corporate Enforcement. The administration’s new FCA Working Group also encourages whistleblowers to report False Claims Act violations in high-priority enforcement areas. Taken together, these programs demonstrate this administration’s intent to prioritize enforcement actions initiated through whistleblower reports, and a willingness to reward whistleblowers in certain circumstances.

The program also underscores the importance for companies to implement and maintain effective antitrust compliance programs. With a greater incentive to file reports with the Division before a whistleblower reports a potential violation internally, companies should ensure that their compliance programs are proactive and targeted at preventing potential misconduct and taking appropriate remedial measures if misconduct is uncovered.

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