DOJ Is Serious About New Criminal Whistleblower Programs Involving Fraud And Antitrust

Key Takeaways

• DOJ is "all-in" on whistleblowers, with new DOJ Criminal Division and Antitrust Division programs expecting companies to detect issues, remediate, and promptly self‑report potential crimes.
• The Antitrust Division's first-ever whistleblower award signals an expansive approach where any antitrust offense involving the mail may qualify for whistleblower awards.
• Companies should urgently reassess compliance programs for early detection, rapid escalation, credible remediation, and alignment with DOJ's 2024 compliance evaluation guidelines.

The U.S. Department of Justice (DOJ) is signaling—through recent whistleblower programs announced by the Criminal Division and the Antitrust Division—that it is "all-in" on whistleblowers and expects companies to detect, remediate, and, where appropriate, promptly self-report potential criminal violations. The Antitrust Division has now issued its first-ever whistleblower reward in a criminal antitrust matter