On January 29, 2026, the Department of Justice’s Antitrust Division announced a $1 million payment to a whistleblower for a bid-rigging conspiracy, marking the DOJ’s first payment under the new Whistleblower Rewards Program. This milestone illustrates the DOJ’s enhanced ability to detect potential anticompetitive conduct, complementing (and reshaping) the enforcement landscape.
The combined force of an expansive Whistleblower Rewards Program and the Antitrust Division’s historically successful Leniency Program places a premium on fast, proactive compliance and decisive remediation. Companies that fail to adapt face heightened enforcement risk from a motivated pool of potential whistleblowers.
The First‑Ever Antitrust Whistleblower Payment
The DOJ awarded $1 million to a whistleblower whose information revealed antitrust and fraud violations at EBLOCK Corporation, an online used‑vehicle auction platform. EBLOCK acquired an undisclosed company, “Company A,” where legacy employees continued an ongoing bid‑rigging scheme with other companies for the online sale of vehicles. The conduct included coordinated suppression of competition and “shill bidding” — fake bids placed to artificially increase sales prices. Despite taking some remedial measures, EBLOCK did not immediately terminate the misconduct following its acquisition of Company A, which allegedly continued for roughly 18 months post‑acquisition. The company ultimately entered into a deferred prosecution agreement and agreed to pay a $3.28 million criminal fine.
In the DOJ’s view, the whistleblower provided original and pertinent information leading to the deferred prosecution agreement and $3.28 million fine, thereby justifying a seven-figure award to the whistleblower. This recognition and whistleblower award indicate a potentially new avenue for enforcing antitrust law outside of the incentives previously afforded under the DOJ’s Corporate Leniency Program. The DOJ award of $1 million to the whistleblower whose information revealed the ongoing fraud highlights the government’s commitment to “support those who provide accurate, actionable intelligence.”
Previously, the Antitrust Division’s Corporate Leniency Program was its most powerful tool for uncovering anticompetitive conduct. Under the program, the first company to self‑report participation in a criminal antitrust conspiracy could receive protection from criminal prosecution provided that the DOJ had not already gathered or received evidence of the criminal conduct from another source. Upon self-reporting, a company would receive a “marker” as first in line for leniency, provided it promptly disclosed, fully cooperated, and remediated misconduct in line with policy objectives. The DOJ’s leniency policy led to significant detection, helping secure billions of dollars in fines and numerous convictions over the past three decades.
But leniency applications have reportedly declined in recent years, prompting the DOJ’s Antitrust Division to broaden its enforcement toolkit. The Whistleblower Rewards Program now adds a mechanism that motivates insiders and other individuals who become aware of potential violations, not just corporations, to be the first movers in reporting to DOJ. This shift alters companies’ strategic calculus. Now, any delay in reporting criminal conduct not only risks that other firms involved in a conspiracy might beat your company in obtaining a first marker under the leniency program but your company also must win the race to report against motivated whistleblowers. The Antitrust Division’s Whistleblower Rewards Program heightens the urgency for companies to strengthen internal compliance and reporting structures.
DOJ’s Whistleblower Rewards Program: Structure and Early Signals
The Antitrust Division recently launched the Whistleblower Rewards Program in July 2025 with USPS partners, offering payments of 15–30% of criminal fines resulting from tips that expose qualifying antitrust or related offenses. To be eligible, the reported information must be:
- Original and voluntary
- Credible and detailed
- Lead to at least $1 million in criminal fines
The program applies to antitrust crimes — including price‑fixing, bid‑rigging, and market allocation — and related fraud or obstruction offenses, provided the conduct has some nexus to USPS (a standard interpreted broadly by the DOJ). Once the mandatory requirements are confirmed, DOJ assesses several additional factors in determining whether a whistleblower qualifies for an award, including the usefulness of the information provided, the whistleblower’s truthfulness and integrity, and the whistleblower’s role or involvement in the underlying conduct, among other factors. In the EBLOCK matter, the whistleblower submitted various documents connected to the scheme that were sent through the mail by Company A and its legacy employees to co-conspirators, which the DOJ treated as sufficient for reward eligibility. This interpretation signals that the USPS element will rarely pose a barrier, and the mere use of mail services in even tangential connection with the alleged illegal conduct may be sufficient.
The new Whistleblower Rewards Program has already spawned an increase in submissions, with Deputy Assistant Attorney General Omeed Assefi noting that the program has had a “massive effect on case generation” since its inception less than a year ago, in July 2025. Accordingly, a race between companies seeking leniency via self-reporting and whistleblowers seeking a financial incentive has been significantly amplified.
The impact of the new Whistleblower Rewards Program extends beyond ongoing business activity into M&A contexts where rapid antitrust due diligence and post‑closing remediation will be more critical than ever. For instance, EBLOCK’s liability arose from misconduct of an acquired firm that was not fully remediated by EBLOCK (the acquiring firm) within 18 months of its acquisition of Company A. This illustrates that failing to detect and promptly address illegal activity can expose company acquirers to DOJ antitrust enforcement and now whistleblower‑triggered scrutiny.
Practical Takeaways for Companies
1. Strengthen and modernize antitrust compliance programs. Given the heightened likelihood of whistleblowing, companies should review and reinforce compliance frameworks, including anonymous reporting channels such as an internal whistleblower hotline, response readiness, and frequent training. In addition to training employees on how to identify and avoid anticompetitive conduct, well-constructed and implemented antitrust compliance programs are considered by the Antitrust Division and may have favorable implications in the Division’s charging decisions or sentencing recommendations.
2. Move rapidly when red flags surface. With whistleblowers incentivized to report early, companies face a compressed timeline to investigate internally, evaluate exposure, and consider voluntary self‑disclosure to preserve potential leniency. If companies wish to self-report and receive criminal leniency, they must act swiftly in recognition of the competing enticements for whistleblowers to report first.
3. Enhance M&A diligence and integration controls. Antitrust diligence must extend beyond financial and commercial review to examine cultural, compliance, and operational practices. Robust due diligence during the M&A process for the risk of anticompetitive conduct is now more important than ever. Integration teams should conduct a risk assessment of internal policies and procedures to determine if remediation is necessary and prioritize early detection of legacy misconduct and take immediate action to mitigate inherited risks.
4. Recognize the broadened universe of potential reporters. The rewards program encourages not only employees but business partners, including vendors, customers, contractors, and other third parties, to come forward. The Whistleblower Rewards Program creates an incentive to report misconduct.
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