Whistleblowers gained new opportunities for financial rewards with the launch of the DOJ’s Corporate Whistleblower Award program. Four categories of fraud — financial system abuse, foreign corruption outside SEC jurisdiction, domestic bribery, and private healthcare fraud — formed the core of the program. Recent DOJ guidelines and case wins show where enforcement priorities really lie.
This article by
TELG principal Janel Quinn and TELG associate Anthony Primelo was published by The Employment Law Group, P.C. on June 26, 2026.
Whistleblowers Welcomed: DOJ’s Corporate Whistleblower Program Fills in the Gaps
By Janel Quinn and Anthony Primelo
IMPORTANT: The following article is intended as a general summary of facts and law and not as individual legal advice upon which you should rely or act. Every case is unique and specific. This article represents our firm’s best knowledge as of June 2026.
The Department of Justice’s Criminal Division launched a powerful new tool in August 2024 with its Corporate Whistleblower Award (CWA) Pilot Program. This was a major move that filled gaps in existing whistleblower award programs, boosted corporate investigations and prosecutions, and opened 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.
When first launched, the CWA program focused on four categories of fraud previously neglected by other whistleblower award programs. The CWA expanded to cover more categories in 2025, which we explored in detail in a previous installment. Here, we’ll focus on the original types of fraud that established the program’s core priorities.
Violations by financial institutions and abuse of the financial system not covered by the Financial Crimes Enforcement Network (FinCEN) whistleblower program
The DOJ’s CWA program is designed to target areas of corporate fraud that fall outside the scope of existing whistleblower programs. To understand where the CWA applies, it is helpful to first identify what is already covered elsewhere. Whistleblowers with information about violations of the Bank Secrecy Act (BSA) or U.S. sanctions, for example, can turn to the Treasury Department’s FinCEN whistleblower program, which specifically covers those types of misconduct.
The BSA requires financial institutions to keep records of negotiable instruments, such as checks or certificates of deposit bought in cash; file reports if total daily transactions exceed $10,000; and report suspicious activity that may signify money laundering, tax evasion, or other criminal activities. The FinCEN whistleblower program focuses on violations of these regulatory and reporting obligations, including failures to maintain an effective compliance program. Such violations may relate to underlying criminal activity, but the FinCEN program does not target criminal schemes so much as noncompliance with BSA requirements.
The FinCEN program also targets financial institutions that violate U.S. economic and trade sanctions. These sanctions can include travel bans, asset freezes, export and import restrictions, arms embargoes, capital restraint, and foreign aid reductions.
In contrast, the DOJ’s CWA program targets the underlying criminal schemes themselves including:
- Money laundering, which is the concealment of illegally obtained funds;
- Bank fraud, such as fraudulent loan applications, identity theft, or counterfeit transactions; and
- Deceiving federal regulatory agencies or impeding their investigations by taking actions like providing false information or concealing relevant details.
The CWA program also investigates failures to properly register as a money services business (also known as a money transmitting business). Companies and individuals who facilitate the transfer of funds from one entity to another — through activities such as selling payment instruments, exchanging currency, transmitting money electronically, or providing bill payer services or accelerated mortgage payment services — are typically required to file FinCEN Form 107 within 180 days of starting operations and renew their registration every two years.
There are some exceptions to the enforcement of this, however — specifically in the cryptocurrency world. The DOJ issued a memo in 2025 indicating that it wouldn’t pursue failures to register in cryptocurrency cases unless the defendant willfully violated the registration requirement. The DOJ also disbanded its cryptocurrency enforcement team, citing an executive order from President Trump.
The DOJ has brought multiple million-dollar cases to fruition in 2025 alone. Brink’s Global Services USA, Inc. — an armored car company specializing in transporting currency and other valuable goods — agreed to pay more than $50 million to settle criminal allegations that it operated as an unlicensed money transmitting business. The Dubai-based Wall Street Exchange Centre LLC agreed to pay more than $9 million after it was investigated for allegedly lying to a U.S. financial institution about its anti-money laundering compliance.
Foreign corruption schemes not covered by the Securities and Exchange Commission (SEC) whistleblower program
The SEC whistleblower program investigates violations of federal securities laws and of the Foreign Corrupt Practices Act (FCPA) if conducted by companies that issue securities — generally U.S. publicly traded companies and foreign companies that offer American Depositary Receipts (ADRs), which represent shares in a foreign company. Typical violations include bribery, improper payments, or accounting misconduct.
Any other kind of company that violates the FCPA would fall under the CWA program. This includes privately held U.S. companies and foreign companies that attempt to bribe U.S. officials.
In early 2025, FCPA investigations were temporarily paused as the Trump administration reassessed how the government enforced the statute. The DOJ issued updated guidelines in June of 2025, directing prosecutors to focus on cases involving identifiable individual misconduct rather than generalized claims that a company’s structure or culture enabled wrongdoing.
The DOJ’s guidelines also introduced priorities to consider when pursuing FCPA cases, including:
- Combating cartels and transnational criminal organizations: prioritizing cases where bribery or corruption facilitates large-scale criminal enterprises, such as drug trafficking or organized crime networks;
- Safeguarding fair opportunities for U.S. companies: focusing on misconduct that gives foreign competitors an unfair advantage over U.S. businesses through bribery or corruption;
- Advancing U.S. national security: targeting corruption that implicates strategic industries, sensitive technologies, or geopolitical interests; and
- Prioritizing serious misconduct: directing resources toward more egregious or systemic violations rather than minor or technical infractions.
FCPA enforcement was ultimately paused for 180 days, but the DOJ followed the hiatus with a major win: a $118 million settlement agreement in November of 2025. The settlement resolved allegations that Comunicaciones Celulares S.A. (Comcel), a Guatemalan telecommunications service provider, bribed government officials in Guatemala. Although the conduct occurred abroad, the FCPA allows the DOJ to assert jurisdiction in cases with a U.S. connection — such as the use of the U.S. banking system or, in the case of Comcel, a significant relationship with the U.S. through a subsidiary.
We expect to see an increase in foreign corruption cases in 2026, particularly those involving companies that are not publicly traded in the U.S.
Domestic corruption schemes committed by or through companies related to the payment of bribes and kickbacks to public officials or employees
The CWA program also covers domestic corruption that involves bribes or kickbacks to U.S. public officials. Federal bribery statutes can extend the umbrella to cover spouses who act as an intermediary or co-conspirator in soliciting or accepting a bribe — as in the case of Nadine Menendez, wife of former U.S. Senator Robert Menendez. She was convicted in September of 2025 for accepting bribes from New Jersey businessmen and ordered to pay nearly $1 million.
There are some limitations to what is considered bribery at the federal level, however. Quid pro quo arrangements are prohibited federally, but after-the-fact “gratuities” are not, according to the Court’s opinion in Snyder v. United States (2024). Thus, providing state or local officials with tokens of appreciation does not constitute bribery under federal law, but state or local governments can still pursue such cases depending on state law.
Health care fraud schemes against private insurance plans or patients
The DOJ has long investigated cases under the federal False Claims Act (FCA), which allows whistleblowers to bring cases on behalf of the U.S. government against companies or individuals who knowingly submit false claims for payment to the government. In 2025, the DOJ recovered $6.8 billion from FCA settlements and judgments, of which $5.7 billion was attributed to health care fraud.
The FCA is meant for government fraud and, therefore, covers fraud against government health insurance programs such as Medicare, Medicaid, and TRICARE. Fraud against private insurance companies or patients was not covered by any federal whistleblower reward program until the introduction of the CWA program.
Now, whistleblowers who have information about fraudulent claims submitted to private health insurance companies — for services not provided or “upcoded” services billed at inflated rates, for example — can bring allegations to the DOJ through the CWA program. Whistleblowers may qualify for a reward if their information results in a financial recovery exceeding $1 million.
The DOJ has signaled that it will also consider allegations regarding fraud against patients, which could include patients being improperly charged for services that insurance has already paid for. The DOJ’s previous actions have focused primarily on recoveries under the FCA, but the financial incentives for whistleblowers are likely to drive increased attention to fraud against private insurance companies and patients.
The CWA program fills gaps left by other whistleblower reward programs and sends a clear message: Whistleblowers are encouraged to come forward with information about a wide range of fraud schemes. Those who do may be eligible for financial awards of up to 30% of the first $100 million recovered, with decreasing percentages thereafter.
The Employment Law Group welcomes potential whistleblowers to discuss their case with our experienced whistleblower attorneys.
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Janel Quinn is a principal at The Employment Law Group, P.C.; Anthony Primelo is an associate at the firm.
