United States: DOJ Antitrust Division Pays $1M to Whistleblower

In brief

The Department of Justice's Antitrust Division (the Division) and the US Postal Service (USPS) granted their first payment under the Antitrust Whistleblower Rewards Program¹ a $1 million award to an individual whose tip helped the Division obtain a Deferred Prosecution Agreement (DPA) and $3.28 million fine against EBLOCK Corporation for bid-rigging and "shill bidding." Documents relating to the alleged scheme were sent through US Mail, satisfying the required USPS nexus for reward eligibility. Announced just six months after the program's launch, this award underscores the Division’s rapid deployment of whistleblower incentives and intensifies the first in race between companies seeking leniency and employees incentivized to report.

Key takeaways

The whistleblower program’s mechanics: individuals who voluntarily provide truthful, original information that results in at least $1 million in criminal fines are presumptively eligible for a reward of 15–30% of the final recovery. Because the USPS administers the program, the misconduct must have a sufficient nexus to the US mail for an award to be available.
The $1 million award is likely to spur further whistleblower activity across industries—Deputy Assistant Attorney General Omeed Assefi noted that the Division has already seen “a frenzy of people coming forward,” underscoring the powerful incentives created by the program.²
The Division's comments linked the whistleblower program to its strategy of accelerating detection, warning that financial incentives may prompt employees to report antitrust violations before their companies do, potentially weakening corporate leverage in leniency negotiations.
Companies should reassess their reporting channels, training, dawn raid readiness, and cartel risk triage procedures.
In this instance, liability stemmed from misconduct by legacy employees at an acquired entity, underscoring the importance of engaging counsel early to conduct robust due diligence for M&A transactions and follow-on integration.

In more detail

On January 29, 2026, the Division announced its first-ever whistleblower reward: a $1 million payment to an individual whose report helped the Division secure a DPA deferred prosecution agreement with EBLOCK Corporation. The company was fined $3.28 million. According to the Division, legacy employees at a company recently acquired by EBLOCK conspired with a competitor to rig bids in used-vehicle auctions, and EBLOCK failed to stop the misconduct. The co conspirators also operated a “shill bidding” scheme, using software generated fake bids submitted under dealer identities that were used without the dealers’ knowledge to artificially inflate consumer prices.

In its press release, the Division emphasized the deterrent and detection value of insider tips, framing whistleblower incentives as a strategic complement—not a substitute—to corporate leniency. Under the Division's Corporate Leniency Policy, Type A leniency applies when a company self-reports before the Division has any information regarding the misconduct and extends non prosecution protection to the company and cooperating current employees. By contrast, once the Division has received information about the conduct from another source, the only available avenue is Type B leniency, which is discretionary and typically affords narrower, non guaranteed individual protections. By demonstrating that the whistleblower program can yield substantial monetary awards, the Division has created strong financial motivations for employees and their counsel to report potential violations ahead of their employers, accelerating the "race to report" as both Type A leniency and whistleblower rewards hinge on being first in the door.

Practical next steps

Tighten internal reporting and triage. Streamline and standardize reporting channels to ensure employees have a confidential and reliable internal system for rapidly escalating red flags. Guarantee a clear path for antitrust counsel to conduct a privileged review of reports within 24-48 hours.³
Accelerate internal decision-making and fact development to preserve Type A leniency eligibility where possible and build contingency tracks—Type B and individual leniency—for situations in which a whistleblower or another company reaches the Division first.
Revisit the leniency playbook. Prioritize Type A leniency, which uniquely affords full non-prosecution protection to the first-in company (and its cooperating current directors, officers, and employees) that reports illegal antitrust activity. However, if the Division already possesses indicia of the conduct—whether from a whistleblower or another company—the best available outcome may shift to Type B leniency, where non prosecution for executives is discretionary and therefore increases potential exposure.
Refresh training on antitrust offenses. Ensure that company management is equipped to recognize early antitrust warning signs before they escalate into conduct requiring external reporting.
Due diligence preacquisition: To mitigate liability risks, companies should engage legal counsel at the earliest stage of any transaction and conduct comprehensive, risk-focused due diligence, particularly regarding legacy employee conduct and compliance practices. This proactive approach is essential for identifying potential issues before integration and safeguarding your organization against unforeseen antitrust risk and liabilities.

Outlook

This award makes clear that the Division intends to move quickly on whistleblower tips to bring cartel and related cases. Companies should anticipate higher tip volume and earlier detection risks, as seen by the "frenzy" of whistleblowers approaching the Division since the announcement of this program. Companies should strengthen internal controls, ensure procurement practices comply with antitrust requirements, mandate rapid escalation to antitrust counsel when red flags surface, and strengthen compliance culture to reduce legal and reputational exposure.⁴

In brief

Key takeaways

In more detail

Practical next steps

Outlook

Related Content