The new program incentivizes individuals to report anticompetitive conduct and signals DOJ is looking for additional avenues to uncover potential violations.
On July 8, 2025, the Antitrust Division of the Department of Justice announced a new Whistleblower Rewards Program that incentivizes individuals to report antitrust violations impacting the U.S. Postal Service (“USPS”). The Rewards Program is available to individuals who provide original information about antitrust violations affecting the USPS that result in more than $1 million in harm.
A whistleblower is eligible for an award in an amount equal to 15–30% of the criminal fine or recovery resulting from their information, depending on the amount of cooperation provided, the usefulness of the information, and the hardship faced by the whistleblower. This could be quite significant depending on the scope of the violation—in the last 10 years, the Antitrust Division’s prosecutions have garnered approximately $5.6 billion in criminal fines. Companies have faced steep fines for antitrust crimes—including upwards of $500 million.
The program does not apply to companies reporting unoriginal information about an eligible criminal antitrust violation, meaning the information is from publicly available sources, already known to the Antitrust Division or the USPS, or previously provided before the Rewards Program was announced. Additionally, the Rewards Program does not apply to companies providing original information if they coerced another party to engage in the illegal conduct they are reporting, or if they were clearly the ringleader or originator of the illegal conduct at issue.
The Rewards Program builds on the Antitrust Division’s leniency program, which allows corporations and individuals to avoid criminal charges if they self-report their participation in an illegal conspiracy and the DOJ had not received that information about the conspiracy from any other source. The Rewards Program also comes after the Antitrust Division keyed in on whistleblowers in its corporate compliance program guidance in November 2024, by highlighting the use of non-disclosure agreements that might deter whistleblowers.
The Antitrust Division’s new program may be limited in comparison to its existing leniency program because of its requirement that a whistleblower show impact to the USPS—though the bar to plead a postal-related antitrust violation appears to be low (not requiring a material harm or substantial detriment to the USPS). The focus on showing a postal-related antitrust violation is in keeping with the DOJ’s focus on rooting out competitive harm to the federal government through its Procurement Collusion Strike Force, of which the USPS is a founding member. The USPS connection also provides a statutory hook to pay whistleblowers because the USPS has statutory authority to offer and pay rewards under existing law.
The addition of the Rewards Program to encourage whistleblowing suggests that the DOJ Antitrust Division is continuing to focus on criminal enforcement and seeking to broaden its investigative tools. The program is consistent with the Trump Administration’s effort urging the DOJ to consider new offers and incentives to encourage corporations and individuals to report unlawful white-collar conduct.
Key Takeaways
- Review corporate compliance programs. Companies should stress test and review corporate compliance programs to reduce gaps in detecting antitrust violations. Additionally, companies should ensure that compliance programs and non-disclosure agreements permit employees to report suspected antitrust violations without fear of retaliation.
- Increased reporting in the U.S. may have international implications. If a whistleblower reports anticompetitive conduct in the U.S. that spans multiple jurisdictions, companies should be prepared to address antitrust compliance across the globe.
- Whole of government approach continues. The addition of a Rewards Program in partnership with the USPS may be a signal that the Trump Administration remains focused on cross-agency collaboration to identify perceived competitive harms against the U.S., state, and local governments that started in his first Administration through the founding of the Procurement Collusion Strike Force in 2019, and continued with the Biden Administrations Executive Order on Promoting Competition in the American Economy in 2021.
- Whistleblower programs in the U.S. have been successful. In 2011, the Securities and Exchange Commission announced a similar whistleblower program, that now receives thousands of tips per year and has since paid more than $2.2 billion to 444 whistleblowers. The success of the SEC whistleblower program should put companies on notice that the Antitrust Division’s Rewards Program could encourage similar reporting and lead to additional regulatory scrutiny.
