Not Just Whistling in the Wind: DOJ’s $1 Million Whistleblower Payout Signals Need for Strengthening Compliance Programs

On Jan. 29, the Department of Justice’s (DOJ) Antitrust Division (Division) announced that its whistleblower program, first announced in July 2025, is paying off (and paying out). The Division reported that it paid a $1 million reward to an individual whistleblower who reported information that led to a deferred prosecution agreement with EBlock, resulting in a $3.28 million criminal fine, though the Division’s press release described the conduct at issue as a “$16 million scheme.” The informant’s identity has not been revealed.

Since the announcement of the whistleblower program in July 2025, the Division has repeatedly touted the idea that the opportunity for whistleblowers to receive a financial reward in exchange for reporting conduct would motivate individuals to come forward and lead to new criminal cases. Six months later, the program is already showing results. Division officials have hinted at the significant number of whistleblowers reporting violations since the program’s inception.

As described in our July 2025 client alert, previously, under the Division’s Leniency Policy, protections were limited to only individuals who admitted that they had participated in the anticompetitive conduct. Whistleblowers, however, do not have to be direct participants in the conduct to qualify for a financial reward. And while the Leniency Policy is still in effect, the Division has essentially upped the ante for individuals within a corporation who believe they may have witnessed or participated in wrongdoing, heavily incentivizing them to report it directly to the DOJ. The Division’s Deputy Assistant Attorney General Omeed Assefi commented that “the race is faster now, because employees and their attorneys are incentivized to blow the whistle and beat their companies to the Division’s doorstep.” — suggesting that a whistleblower may cause a company to be ineligible for leniency. 

This announcement serves as a strong reminder that investing in effective compliance programs is more important now than ever. Companies should consider whether their compliance programs have effective mechanisms to detect potential criminal antitrust violations, whether employees are able and incentivized to report potential violations internally, and whether those reports are being adequately addressed.

Paul Hastings will continue to monitor the effects of the Division’s whistleblower programs, and how the DOJ’s recent push for self-reporting impacts companies.