Whistleblower | Antitrust

The Department of Justice’s New Antitrust Whistleblower Program

In 2025, the U.S. Department of Justice (DOJ) launched a new Antitrust Whistleblower Rewards Program to encourage individuals to report criminal antitrust violations. This new program complements the DOJ’s long-standing Corporate Leniency Program by opening a path for individuals—not just corporations—to play a role in uncovering and prosecuting business cartels. For employees or others with knowledge of anticompetitive schemes, the program offers the possibility of a substantial financial reward.

Whistleblowers can receive financial awards of 15–30% of the monetary penalties the government recovers, provided their information is original, voluntary, and leads to a recovery of more than $1 million.

What Conduct Does the Program Cover?

The program targets criminal violations of the Sherman Act and related offenses, including:

• Price-Fixing – Agreements among competitors to set common prices (usually to raise or stabilize them), price formulas, or price-related terms (such as discount limits).
• Wage-Fixing – A form of price-fixing specific to labor markets, where employers conspire to set or suppress wages.
• Bid-Rigging – Collusive schemes where potential buyers who should be bidding against each other competitively instead agree on the top bids they’ll submit, or which auctions they’ll bid in and which they’ll stay out of so their co-conspirators can win them (sometimes known as “bid rotation” schemes).
• Market Allocation – Schemes dividing up markets, customers, or territories.
• No-Poach Agreements – Competitors agreeing not to recruit or hire one another’s employees.

These conspiracies can be extremely difficult to detect and are often uncovered only when insiders step forward to blow the whistle.

Whistleblowers are Essential and Rewarded

Whistleblowers play a critical role in exposing cartels and driving accountability. And they can be handsomely rewarded.

• Exposing Secret Agreements – Bringing forward emails, meeting notes, or firsthand accounts that reveal collusion.
• Protecting Consumers and Workers – Helping end practices that inflate prices, depress wages, and stifle fair competition.
• Ensuring Accountability – Triggering criminal enforcement that deters future misconduct.

Earning an Award

If the information provided leads to the government bringing a criminal enforcement action that results in more than $1 million in fines or other recoveries, the whistleblower may be awarded, at the discretion of the Antitrust Division, an amount presumptively totaling between 15% and 30% of the government’s recovery.

How We Help

At Cohen Milstein, we have a practice group dedicated to representing individuals who provide information to the government through whistleblower award programs, such as the new U.S. DOJ Antitrust Division’s Whistleblower Rewards program.

We guide whistleblowers through every step of the government’s process:

• Assessment of Claims – Evaluate whether your claims fall within the scope of the Antitrust Division’s program.
• Preparation of Submission – Compile evidence and draft a written submission in accordance with the procedural rules of the program that presents your critical information and analyzes the relevant legal framework to clearly demonstrate to the Antitrust Division that it should open a criminal investigation into your claims.
• Dedicated Representation Throughout the Process – Interact with government attorneys during their investigation to answer their questions and assist in their enforcement action.
• Maximize Your Award – Leverage our insights into both the Antitrust Division’s criminal prosecution practices and government whistleblower programs more broadly to advocate at every step in the process for your entitlement to the highest possible award amount.

We have a deep understanding of how government prosecutors evaluate whistleblower tips, structure investigations, and build criminal cases. That perspective allows us to anticipate the government’s priorities and help you present information in the most effective way.

We bring together a powerful team of antitrust and whistleblower attorneys to guide you through every step of this program—both substantively and procedurally. Our Antitrust team is widely recognized as one of the strongest plaintiff-side practices in the country and includes former DOJ Antitrust Division attorneys with both civil enforcement and criminal prosecution experience. They work side by side with our seasoned whistleblower attorneys, who have helped countless clients succeed in a range of federal and state whistleblower programs. Together, this team offers the insight, skill, and commitment needed to protect your interests and achieve results.

Our attorneys deliver the experience, strategy, and dedication needed to protect your interests and achieve meaningful results.

If you have knowledge of price-fixing, wage-fixing, bid-rigging, market allocation, no-poach agreements, or other antitrust violations, we can help you safely report the misconduct and pursue a financial award. Contact us for a Confidential Consultation.