First Payment Under DOJ Antitrust Whistleblower Rewards Program Highlights New Reporting Incentives

On January 29, 2026, the U.S. Department of Justice (“DOJ”) Antitrust Division, in partnership with the U.S. Postal Service (“USPS”), announced the first-ever payment under the Antitrust Division’s Whistleblower Rewards Program (the “Rewards Program”): a $1 million reward to an individual who reported information that led to criminal antitrust and fraud charges against an online vehicle auction company. This reward demonstrates that the Antitrust Division is committed to rewarding whistleblowers for reporting criminal antitrust violations and underscores the Rewards Program’s potential to drive more enforcement actions. In addition, the Rewards Program may heighten the urgency for companies to self-disclose misconduct and make effective internal controls even more essential.

The Antitrust Division announced the creation of the Rewards Program on July 8, 2025, with former Assistant Attorney General Gail Slater stating that it was intended to “create a new pipeline of leads from individuals with firsthand knowledge of criminal antitrust and related offenses.” For the first time, the Rewards Program makes monetary payments available to whistleblowers who voluntarily report original information about criminal antitrust violations and related offenses. Pursuant to a Memorandum of Understanding (“MOU”) between the Antitrust Division and the USPS, the offenses must affect “the Postal Service, its revenues, or property” to satisfy the nexus to statutes authorizing monetary payments to whistleblowers. To be eligible for a reward, a whistleblower must meet specified criteria, including not having been the “leader or originator” of the criminal conduct. The reported information must be derived from the whistleblower’s independent knowledge and not already known to the Antitrust Division or the USPS. Further, the reported information must result in criminal fines or other recoveries of at least $1 million. According to the MOU, the amount of a reward remains “in the sole discretion of the Antitrust Division,” but “the presumption will be that the total reward will be at least 15 percent of the recovered criminal fine” and no more than 30 percent.

The first whistleblower to receive a payment under the Rewards Program reported original information about a bid-rigging and fraud scheme involving EBLOCK Corporation (“EBLOCK”), an online auction platform for used vehicles. In November 2020, EBLOCK acquired another unnamed online vehicle auction platform. Individuals at the acquired company allegedly conspired with individuals at a third company to engage in a $16 million “shill bidding” scheme to artificially inflate the auction prices of used vehicles. According to the Antitrust Division, individuals at the acquired company and the third company exchanged confidential bidding information, coordinated to place fake bids on a shared inventory of vehicles, and even commissioned the development of software that automatically placed fake bids under the names of real auto dealerships without the dealerships’ consent. Individuals at the acquired company and the third company allegedly pooled and split the profits from the scheme. Moreover, the co-conspirators allegedly sent documents in support of the scheme through the U.S. mail, satisfying the required nexus for a whistleblower reward. The Antitrust Division alleges that EBLOCK executives first learned of the coordinated bidding activity on January 21, 2021, but did not fully end the scheme until February 2022.

On January 22, 2026, the Antitrust Division filed a deferred prosecution agreement (the “Agreement”) with EBLOCK in the U.S. District Court for the Central District of California. The Agreement resolves criminal Sherman Act and wire fraud charges under 15 U.S.C. § 1 and 18 U.S.C. § 1343, respectively. The Agreement requires EBLOCK to implement an appropriate compliance program, cooperate with an ongoing DOJ criminal investigation, and pay a $3.28 million fine, among other measures. The $1 million whistleblower reward represents just over 30 percent of the assessed fine, above the high end of the presumptive reward range set forth in the MOU, and indicating that the Antitrust Division intends to provide significant payments to whistleblowers. However, the announcement of the reward and the Agreement provide little detail about the whistleblower, the information the individual provided, and how that information led to the criminal charges.

This reward highlights the expanded incentives for whistleblowers to report antitrust violations, which could lead to more criminal enforcement actions. Indeed, on January 29, 2026, Deputy Assistant Attorney General Omeed A. Assefi made public remarks describing “a frenzy of people coming forward to qualify under the whistleblower program.” In addition, the Rewards Program is merely one part of a proliferation of DOJ and other whistleblower programs implemented in recent years. Further, the Rewards Program complements the Antitrust Division’s existing Leniency Policy, which provides protection from prosecution to individuals and organizations that make voluntary self-disclosures and cooperate in criminal antitrust investigations. Pursuant to the Antitrust Division Leniency Policy and Procedures, an organization qualifies for the most complete, or Type A, form of leniency, only if the Antitrust Division has “not received information about the illegal activity from any other source” at the time of a self-disclosure. Accordingly, the Rewards Program and the Leniency Policy can together encourage a “race” between whistleblowers and corporations to make the first report to DOJ.

In light of heightened enforcement risks, companies should ensure that they have implemented an effective compliance program and internal controls. The EBLOCK matter specifically signals the need for effective M&A due diligence and post-acquisition compliance monitoring to ensure that companies do not assume liability for an acquired firm’s antitrust violations. When companies do discover misconduct, they should move quickly to investigate the matter and consider self-reporting before a whistleblower wins the disclosure race. Companies should also maintain and regularly promote internal reporting channels to receive early warning of potential compliance issues. This first-announced payment under the Rewards Program confirms that incentives for whistleblowers to report antitrust violations are real and valuable, and that companies without adequate compliance systems can end up paying the price.