Game Changer: What DOJ’s Antitrust Whistleblower Rewards Program Means for Corporate Compliance Programs

In July 2025, the DOJ Antitrust Division announced its first-ever whistleblower rewards program as a new tool to incentivize the reporting of antitrust criminal offenses.  Within seven months, this program resulted in a whistleblower receiving a $1 million reward and a corporate plea in a bid rigging investigation.  The Antitrust Division has described its adoption of whistleblower programs as making the race to report criminal antitrust offenses “faster” by creating a new lane where whistleblowers have a financial incentive to disclose to prosecutors unlawful conduct before corporations seeking the benefits of the Division’s Leniency Program.  Given that employees now have a significant financial incentive to report antitrust criminal offenses to prosecutors instead of their employers, the Antitrust Division’s whistleblower program creates new issues that companies must address as they seek to implement effective antitrust compliance programs and preserve the ability to secure leniency in criminal antitrust investigations.  This panel of experienced in-house and outside counsel, which includes former Antitrust Division prosecutors, will discuss the issues that companies and their counsel must consider when developing and implementing antitrust compliance programs in the age of whistleblower rewards programs and best practices for addressing these issues.

The panel discussion will be followed by a cocktail reception.

Faculty

Juan A. Arteaga, Moderator, Partner, Sidley Austin LLP

Ryan Danks, Partner, WilmerHale LLP

Dean V. Hoffman, Executive Director, Global Head of Antitrust Compliance, JPMorgan Chase & Co.

Mike Koenig, Global Chief Ethics and Compliance Officer, JBS

Eyitayo “Tee” St. Matthew-Daniel, Partner,  Paul, Weiss, Rifkind, Wharton & Garrison LLP