The Antitrust Division’s New Whistleblower Rewards Program: Misconceptions, Leniency, and the New Race to Report
The Department of Justice Antitrust Division’s Whistleblower Rewards Program has attracted significant attention since its launch in 2025 and following the Division’s announcement of its first whistleblower reward less than a year later. The program fundamentally alters the timeline of criminal antitrust investigations by financially incentivizing employees and former employees to approach the Division prior to a company completing an internal investigation, assessing exposure, or making leniency decisions. Since its launch, considerable attention has focused on how the program works and what it means for corporate compliance and leniency. Within that discussion, some misconceptions have emerged regarding both whistleblower eligibility and the program’s practical effect on antitrust investigations . As one of the former Division officials involved in launching and implementing the program, I believe those misconceptions obscure what may be the program’s most significant consequence: it...