DOJ’s Criminal Corporate Whistleblower Program: A New Tool in the Fight Against Fraud
In August 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (“Program”) to uncover and prosecute corporate crime, fill the gaps of then-current whistleblower programs, and to incentivize those with information about corporate criminal wrongdoing to report original information about criminal conduct that might otherwise go undetected or be difficult to prove.
The Program was focused initially on four areas: “(1) certain crimes involving financial institutions and their employees; (2) foreign corruption involving privately held companies and others that are not issuers of U.S. securities; (3) domestic corruption involving companies; and (4) healthcare fraud schemes targeting private insurers not subject to qui tam recovery under the False Claims Act.” On May 12, 2025, the Department expanded the scope of the Program to include trade, tariff and customs fraud, and federal immigration law violations, among others.
The Program is a three-year initiative managed by the Criminal Division’s Money Laundering and Asset Recovery Section. Whistleblower awards are issued at the Department’s sole discretion. A whistleblower may be eligible for an award of up to 30% of the first $100 million in net proceeds forfeited and an award of up to 5% of any net proceeds forfeited between $100 million and $500 million. There is a presumption that the Department will award a whistleblower the maximum 30% of the first 10 million in net proceeds forfeited. A whistleblower is not eligible for an award on net proceeds forfeited above $500 million.
In August 2024, the Department said it would “publish information about all successful forfeitures in corporate resolutions in the designated programmatic areas at www.justice.gov/corporatewhistleblower.” Now, two years into the three-year pilot program, there are no public reports indicating the Department has issued any whistleblower rewards pursuant to the Corporate Whistleblower Awards Pilot Program.1
However, on January 29, 2026, the Department announced its first-ever whistleblower reward under the Department’s related Antitrust Division Whistleblower Rewards Program. A whistleblower’s report led to charges, a deferred prosecution agreement, and a $3.28 million fine against an international corporation. The whistleblower received a $1 million reward. The Antitrust Division’s Program was announced on July 8, 2025.
In July 2026, the Department announced that the Trade Fraud Task Force surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in less than one year. The announcement reinforces the Department’s commitment to holding fraudsters accountable by pursuing both criminal prosecution and civil enforcement.
With only a year left of the three-year pilot program, it will be interesting to see when, and if, the Department announces any whistleblower awards pursuant to the Corporate Whistleblower Awards Pilot Program.
This piece was written by Gia Grimm, a Senior Counsel at Joseph Greenwald Laake
1 Information is current as of the date of this publication.
