Million-Dollar U.S. DOJ Antitrust Reward Underlines Broader and Growing Commitment to Incentivize Corporate Whistleblowers

Within seven months of announcing its groundbreaking monetary whistleblower awards program for individuals who report potential violations, on January 29, 2026, the U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Postal Service announced the first whistleblower award under the Antitrust Whistleblower Rewards Program, paying $1 million to an individual whose information led to criminal enforcement action. The award, approximately 30% of the $3.28 million criminal fine imposed on EBLOCK Corporation, marks a milestone in DOJ’s expanding use of whistleblower incentives. This resolution also highlights the program’s broad nexus standard, under which the alleged violation must affect the Postal Service, its revenues, or its property. This shows that for a whistleblower to receive an award, there need not be material or substantial harm to the Postal Service so long as the U.S. mail was used in connection with the reported scheme.

This announcement closely follows DOJ’s January 2026 announcement of its annual False Claims Act (FCA) enforcement statistics, which reported a record for recoveries over the history of the FCA and a historically high number of qui tam filings by relators/whistleblowers. Together with the Corporate Whistleblower Awards Pilot Program launched by DOJ’s Criminal Division in 2024 and discussed in a prior Sidley article — and expanded by the Trump administration in 2025 — these developments reflect a continued and increasingly coordinated incentive structure across DOJ enforcement divisions for whistleblowers to surface complex forms of alleged misconduct.

Viewed collectively, the Antitrust Whistleblower Rewards Program award, record FCA activity, and the ongoing Corporate Whistleblower Awards Pilot Program underscore that whistleblower programs have become an established feature of DOJ’s enforcement toolkit across both civil and criminal matters. In addition, the U.S. Securities and Exchange Commission and other regulatory agencies continue to maintain robust whistleblowing programs, all of which demonstrate why companies should carefully assess internal reports, conduct investigations, and weigh self-disclosure decisions.

I. DOJ’s Antitrust Whistleblower Rewards Program and the EBLOCK Case

  In July 2025, DOJ’s Antitrust Division and the U.S. Postal Service jointly announced a new Antitrust Whistleblower Rewards Program, relying on statutory authority tied to conduct that affects the Postal Service. As discussed in a prior Sidley article, the program reflects DOJ’s expansion of whistleblower incentives and more closely aligns antitrust enforcement with longstanding whistleblower frameworks in securities, commodities, and FCA enforcement. The program authorizes financial awards to individuals who provide original information leading to criminal antitrust penalties, including fines, forfeiture, or restitution, provided the government ultimately collects at least $1 million. A whistleblower may receive up to 30% of the collected criminal penalty, with DOJ guidance reflecting a presumptive award range of 15% to 30%, depending on factors such as the significance of the information and the whistleblower’s cooperation. While whistleblowers will be motivated by this potential payout, corporations are also incentivized to self-report because of the Antitrust Division Leniency Policy, which gives members of a conspiracy an incentive to come forward to avoid criminal liability through a potential nonprosecution agreement. 

In the case of EBLOCK, the whistleblower alerted DOJ to a potential bid-rigging conspiracy. EBLOCK, which operates an online wholesale car auction platform, acquired Company A in November 2020. Following the acquisition, EBLOCK learned in January 2021 of the ongoing bid-rigging conspiracy involving Company A and another firm, Company B, took steps to prevent it from continuing, but did not fully stop the conduct until February 2022. According to DOJ, Company A employees conspired with the principal at Company B to suppress competition in violation of Section 1 of the Sherman Act. This conspiracy included “shill bidding,” or the submission of artificial bids designed to inflate auction prices, giving rise to related wire fraud charges. The scheme involved the sharing of confidential bidding information, providing competitors with unauthorized system access, and the use of software tools to submit fraudulent bids in the names of legitimate dealers. Triggering the Postal Service nexus, the defendant used the U.S. mail to send documentation related to the scheme. Taken together, the EBLOCK whistleblower award indicates that DOJ could view ordinary commercial reliance on mail in auctions, procurement, or transactions as sufficient to satisfy the Postal Service nexus even where the Postal Service is not the focal point of the alleged misconduct.

The EBLOCK award also comes against the backdrop of increased whistleblower activity, including a record number of qui tam filings under the False Claims Act in 2025. Viewed in context, these developments point to an enforcement landscape in which financial incentives play an increasingly prominent role in surfacing potential misconduct across DOJ civil and criminal matters.

II. Key Takeaways and Practical Considerations

1. DOJ’s first antitrust whistleblower award signals an expanding role for insider reporting in antitrust enforcement, consistent with broader DOJ enforcement activity that increasingly incorporates insider reporting.

The award suggests that insider reporting is likely to remain an increasing driver of enforcement risk. In antitrust matters, whistleblower incentives now operate alongside existing enforcement frameworks that solicit insider information, such as in government procurement, where the Procurement Collusion Strike Force continues to solicit tips and coordinate investigations across agencies. This development aligns with broader DOJ enforcement trends, including significant whistleblower activity under the FCA, and underscores that companies should expect whistleblower-driven reporting to be an increased feature of the enforcement landscape.

2. The reach of the Antitrust Whistleblower Rewards Program may be broader than expected. 

 The first-ever antitrust whistleblower reward reflects a broad interpretation of the statutory requirement that conduct must affect the U.S. Postal Service, indicating that any use of the Postal Service in connection with a scheme may be sufficient to satisfy the nexus requirement. As a result, conduct involving auctions, procurement, or marketplace transactions could readily fall within the program’s scope so long as the U.S. mail was used in connection with the conduct, potentially extending the program’s relevance to a wide range of scenarios.

3. DOJ’s whistleblower frameworks collectively heighten the practical downsides of delaying investigations once internal allegations arise.

Across the Antitrust Whistleblower Rewards Program, the Corporate Whistleblower Awards Pilot Program, and FCA enforcement, whistleblower incentives increase the likelihood that unresolved internal concerns will be reported directly to enforcement authorities. Once external reporting occurs, companies may have less ability to influence the timing, scope, and framing of their engagement with DOJ. In this environment, delay following internal allegations increases enforcement risk. Companies therefore need to move promptly to preserve evidence, conduct a credible investigation, and reach informed decisions about next steps. 

DOJ has explicitly reinforced these timing considerations. Under the Criminal Division’s Corporate Whistleblower Awards Pilot Program and Corporate Enforcement and Voluntary Self-Disclosure Policy, both last updated in 2025, voluntary self-reporting within specified timeframes, including a 120-day period following internal whistleblower disclosures, may preserve eligibility for corporate declinations should a company choose to self-report (assuming other policy criteria are met). In the antitrust context, while the 120-day concept protects whistleblower eligibility rather than guaranteeing a more beneficial outcome for the company, delays in investigating and assessing internal allegations increase the likelihood of direct reporting to DOJ — as the whistleblower will try to remain within that 120-day frame. 

These whistleblower regimes operate in parallel with DOJ’s analysis under the Evaluation of Corporate Compliance Programs (ECCP). The Criminal Division’s and Antitrust Division’s respective ECCPs use substantially similar language in emphasizing how prosecutors will assess a strong speak-up culture, effective internal reporting mechanisms, and protection against retaliation. In practice, DOJ evaluates not only whether misconduct occurred but whether employees have a credible, trusted pathway to raise concerns internally and whether the company responds in a way that encourages reporting rather than driving it outside the organization. As a result, timely, coordinated internal responses supported by credible investigative work serve a dual function: They reduce the likelihood of external whistleblower reporting and position the company more favorably under DOJ’s compliance program analysis when engaging with enforcement authorities.

The breadth of the new Antitrust Whistleblower Rewards Program further heightens this pressure. Corporations now know that employees, and potentially industry competitors, have stronger incentives to report directly to DOJ, increasing the stakes of delay and reinforcing the importance of prompt investigation; escalation; and, where appropriate, cooperation under the Leniency Policy.

4. Recent workforce reductions heighten whistleblower risk.

As a practical matter, reductions in force, restructurings, and layoffs have long been associated with increased whistleblower reports. Employees facing termination or job uncertainty may be more likely to report perceived misconduct externally, particularly where prior concerns were unresolved or confidence in internal reporting channels is low. In periods of workforce disruption, companies should be especially focused on promptly investigating internal allegations, reinforcing antiretaliation protections, and ensuring that speak-up mechanisms are credible and well communicated.