DOJ’s first whistleblower payout signals a new era of antitrust enforcement

The United States Department of Justice (DOJ) Antitrust Division announced the first monetary award under its new Whistleblower Rewards Program (Program) on January 29, 2026. The DOJ awarded $1 million to an individual whose report led to a deferred prosecution agreement with EBLOCK Corporation (EBLOCK), requiring the company to pay a $3.28 million criminal fine for bid‑rigging and fraud.

This first payout may signal a shift in criminal antitrust enforcement. By introducing a meaningful financial incentive for individuals to report misconduct, the DOJ’s Program has accelerated the race to the courthouse. In response, companies confronted with potential internal wrongdoing are encouraged to emphasize a timely and decisive response and take proactive steps to mitigate greater risk.

Below, we discuss the Program, the EBLOCK case, and what companies can do to prepare for heightened enforcement.

Background: A new race to report

For decades, the DOJ’s primary criminal enforcement tool has been its Corporate Leniency Program, which created a race among companies to self-report in exchange for non-prosecution protection. The new Whistleblower Rewards Program, launched in July 2025 in partnership with the US Postal Service (USPS), adds a new competitor to that race: the individual insider.

Three events must occur for an individual to qualify for a reward:

1. New and original information: The whistleblower must voluntarily provide new and original information about a potential criminal antitrust violation.


2. Minimum fine requirement: The reported conduct must result in a criminal fine or recovery of at least $1 million.


3. “Nexus” with USPS: The violation must have a nexus to the USPS, requiring the USPS Inspection Service to identify a “specific and credible harm to the USPS, though the harm need not be substantial or material.”

Successful whistleblowers may receive a reward of up to 30 percent of the money collected. As this first case demonstrates, the potential payouts are substantial and will likely inspire a wave of new reports. According to one senior DOJ official, the Program already has a “massive effect on case generation,” with the Division “seeing a frenzy of people coming forward.”

EBLOCK: Post acquisition antitrust exposure and the whistleblower trigger

The EBLOCK case provides a stark illustration of the new enforcement reality. EBLOCK, a digital used car auction service, acquired another online auction platform, Company A, in November 2020. According to the DOJ, Company A legacy employees were allegedly engaged in a bid-rigging conspiracy with a competitor, Company B, and placed fraudulent “shill bids” to artificially inflate vehicle prices.

According to the DOJ, EBLOCK did not take “immediate action” to stop the conduct after the acquisition. An insider reported the illegal scheme, which affected an estimated $16.2 million in sales, through the new Program. The DOJ established the necessary jurisdictional hook based on the conspirators’ use of USPS to transmit scheme‑related documents. This suggests the “postal nexus” requirement is a low bar that will allow the Program to reach misconduct across nearly every sector of the economy.

Key takeaways

The EBLOCK case and the launch of the Program suggest a potential roadmap of the DOJ’s enforcement priorities. Companies are encouraged to consider the following proactive steps:

1. Recognize the materially increased risk of detection: The possibility of a multi-million-dollar payout creates an unprecedented incentive for employees – your own, your competitors’, or your partners’ – to report misconduct. Companies are encouraged to operate under the assumption that wrongdoing is more likely than ever to be exposed.


2. Make antitrust a focal point of M&A due diligence: EBLOCK inherited its criminal liability through an acquisition. This case underscores that acquiring a business means inheriting its antitrust risk. Due diligence can no longer stop at signing; it includes a prompt and thorough post-acquisition investigation to identify and dismantle any problematic conduct. Acquirers are encouraged to take an aggressive approach to compliance diligence to avoid inadvertently acquiring a criminal investigation.


3. Invest in a culture of internal compliance and reporting: Now more than ever, the best defense is a proactive offense. Maintaining robust, effective compliance programs that encourage employees to raise concerns in-house may prove critical for preventing investigation. Creating trusted internal reporting channels provides opportunities to investigate potential violations, remedy them, and strategically decide whether to self-report under the Corporate Leniency Program – before a whistleblower has a chance to notify the DOJ.

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DLA Piper’s Antitrust and Competition practice helps businesses achieve their goals without jeopardizing compliance with federal, state, and international antitrust and competition laws.

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