The DOJ Antitrust Division’s newly launched whistleblower reward program, first announced in July 2025, is expected to drive increased whistleblower activity. It offers eligible informants up to 30% of penalties in cases with recoveries over $1 million. The program’s inaugural whistleblower award may embolden additional informants by providing the clarity and reassurance needed to risk their careers to support suspected antitrust violations. The program may speed investigations by providing probative evidence to prosecutors early in the process and accelerating reporting, while pushing companies seeking leniency to think very critically about not self-reporting.
Ann O’Brien, co-leader of Sheppard’s Antitrust and Competition practice group, described the program’s “rollout to payout” as impressive but warned of potential trial risks and “false positives,”— reports to the DOJ that are insufficient to prove criminal conduct. In a jury trial, DOJ witnesses could face cross-examination over whether a whistleblower award constituted payment for testify. “It’s about the quality of the information, and now you’re paying for it,” O’Brien said.
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