The DOJ’s new Corporate Whistleblower Award program targets fraud, bribery, money laundering, and more, filling key gaps in existing whistleblower award programs and creating many new potential avenues for whistleblowers to secure justice and compensation.
This article by TELG principal Janel Quinn and TELG associate Anthony Primelo was published by The Employment Law Group, P.C. on August 7, 2025.
By Janel Quinn and Anthony Primelo
The Department of Justice’s Criminal Division launched a powerful new tool in August 2024 with its Corporate Whistleblower Award (CWA) Pilot Program. This is a major move that will fill gaps in existing whistleblower award programs, boost corporate investigations and prosecutions, and open the door to more monetary awards for whistleblowers.
The DOJ’s CWA program promises whistleblower awards based on a percentage of the net proceeds forfeited by fraudsters. This rewards model resembles the Securities and Exchange Commission’s (SEC’s) own whistleblower award program, which has led to the agency collecting over $6.3 billion in monetary sanctions since its launch in 2011 and paying whistleblowers over $2.2 billion in awards.
The DOJ Criminal Division’s program originally covered four categories of fraud previously neglected by other whistleblower award programs:
The DOJ amplified its interest in the program and added four new categories of covered fraud following Donald Trump’s inauguration in 2025, including:
Let’s break down each fraud category a bit more.
1. Violations by financial institutions and abuse of the financial system not covered by the Financial Crimes Enforcement Network (FinCEN) whistleblower program
The FinCEN whistleblower award program only covers violations of the Bank Secrecy Act as well as U.S. sanctions violations, focusing mainly on issues with respect to deficient compliance programs and specific sanctions.
The DOJ’s new CWA program more broadly targets criminal schemes by institutions and insiders, including money laundering, bank fraud, obstruction or defrauding of federal regulators, and failure to register as a money transmitting business. This swings the door wide open for whistleblowers to potentially get a share of the recovery.
In 2023, the DOJ secured a $1.6 billion asset recovery from Binance Holdings Limited for its failure to register as a money transmitting business. In 2022, the DOJ recovered $2 billion in assets from Danske Bank for defrauding U.S. banks through money laundering. And, in 2018, the DOJ obtained a $360 million asset recovery from Rabobank National Association for concealing deficiencies in its anti-money laundering program.
While these recoveries (and the recoveries noted in the other examples that follow) were not made under the new award program, they reflect the scale of misconduct the DOJ is pursuing — and the kinds of cases that could now trigger significant whistleblower payouts.
2. Foreign corruption schemes not covered by the SEC whistleblower program
The SEC and the DOJ have focused efforts on prosecutions for violations of the Foreign Corrupt Practices Act (FCPA), with the SEC focusing more on civil cases related to accounting provisions and the DOJ focusing more on criminal cases.
In 2024, the DOJ recovered $287 million in assets and $374 million in criminal monetary penalties from Gunvor S.A., an international commodities trading company based in Switzerland, for FCPA violations related to bribery. In 2023, the DOJ recovered $30 million in assets and $68 million in criminal penalties from Freepoint Commodities LLC for similar bribery allegations under the FCPA.
3. Domestic corruption schemes committed by or through companies related to the payment of bribes and kickbacks to public officials or employees
The DOJ now welcomes whistleblowers who have information about corrupt domestic officials in addition to providing information regarding corruption foreign officials with connections to the U.S.
In 2024, the DOJ recovered over $1 billion in assets from financing company 1Malaysia Development Berhad in connection with embezzlement, bribery, and money laundering, as well as $4 million in assets from Tommy and Bontiea Goss for bribery of elected officials in the state of Arkansas.
4. Health care fraud schemes against private insurance plans or patients
The DOJ now can utilize the CWA program in addition to the federal False Claims Act (FCA) and its whistleblower program to prosecute companies and people who defraud federal health care programs.
In 2024, the DOJ announced a National Health Care Fraud Enforcement Action totaling over $2.75 billion in false claims, many of which were submitted to private health insurance companies. The DOJ charged 126 defendants as part of that action with defrauding, in part, private insurance companies for treatments that were medically unnecessary or never provided.
5. Violations by or through companies related to trade, tariff, and customs fraud
This is the first of the four new categories put in place by the DOJ’s 2025 updated guidance and is directly aligned with the current administration’s focus on increased tariffs and the general restructuring of the country’s international trading practices.
President Trump’s proposed “reciprocal” tariff increases are in flux, but the U.S. Court of Appeals for the Federal Circuit has allowed the tariffs to remain in place while they are challenged in the courts. Nevertheless, the DOJ will now welcome whistleblower submissions where importers evade U.S. tariff, customs, and trade barriers. A recent $8.1 million DOJ recovery for evading customs duties indicates that the DOJ is already starting to prioritize such actions.
6. Violations by or through companies related to federal immigration law
The new administration included violations of federal immigration law as one of the other categories of focus for the CWA program. While immigration enforcement has historically largely been left to U.S. Immigrations and Customs Enforcement, the DOJ will presumably be taking on a larger role in investigations and enforcement. One case from 2017 resulted in a $95 million recovery, including $80 million in criminal forfeiture and $15 million in civil payments.
7. Violations by or through companies related to sanctions offenses, material support of terrorism, or cartels and transnational criminal organizations including money laundering, narcotics, Controlled Substances Act, and other violations
The new administration signaled a renewed focus on prosecuting cartels and violations of the Controlled Substance Act, which regulates the manufacture, importation, possession, use, and distribution of specific substances.
In 2022, the DOJ reached a $4.3 million settlement with Sovah Health for allegations regarding a failure to have effective controls in place preventing the diversion of prescription opioids. And, just this year, the DOJ announced a $200 million recovery stemming from an international ring of dark web vendors, buyers, and administrators involving over two metric tons of drugs.
8. Violations by or through companies related to fraud against, or the deception of, the United States in connection with federally funded contracting or federal programs, where such fraud does not involve health care or illegal health care kickbacks
The DOJ’s inclusion of this category in its updated guidance likely serves as a catch-all to cover any other type of fraud against the federal government outside the health care space. Fraud against government health care programs typically represents the majority of FCA recoveries, accounting for 57% of the total recoveries under the FCA in 2024. This signals that the DOJ is considering tools outside the FCA’s whistleblower award program when it comes to prosecuting fraud against the federal government.
While the DOJ’s updated guidance provides clarity regarding the CWA program’s continued existence and its areas of focus, there are still many looming questions, including:
The DOJ is still finalizing the program’s details. It has not yet published claim forms on its CWA program webpage nor has it published a list of applicable enforcement actions under which whistleblowers can apply for awards, but whistleblower advocates are optimistic that the program will become a flagship channel to report fraud.
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Janel Quinn is a principal at The Employment Law Group, P.C.;Anthony Primelo is an associate at the firm.
