Legal Representation for Corporate Whistleblowers

In 2024, the U.S. Department of Justice’s (DOJ) Criminal Division launched the Corporate Whistleblower Awards Pilot Program to encourage individuals to report federal corporate crime. The program represents a major development in federal enforcement policy and opens the door for whistleblowers — especially, though not exclusively, those with insider knowledge — to come forward with greater protection and potentially significant financial rewards.

Hagens Berman represents whistleblowers reporting fraud and other illegal conduct under this new DOJ Pilot Program. Our whistleblower attorneys have extensive experience in whistleblower law and working with federal authorities, including the Department of Justice’s Criminal and Civil Divisions, and we have the resources to investigate, develop and advance your whistleblower claim effectively. We are here to help you navigate the risks, protect your rights and maximize your potential reward.

In May of 2025, the Trump Administration changed some of the priorities and practices of the Department of Justice whistleblower program in important ways that whistleblowers must consider.

What is the Corporate Whistleblower Awards Pilot Program?

The DOJ’s new Pilot Program is a three-year initiative that allows eligible individuals to receive financial awards for voluntarily providing original information about corporate crime. To be eligible for an award under this new DOJ program, the whistleblower’s information about criminal misconduct relating to one or more designated program areas must lead to the government’s successful recovery, through forfeiture, in excess of  $1 million. The program is run by the DOJ Criminal Division’s Money Laundering and Asset Recovery Section.

As amended in 2025, the DOJ Pilot Program allows for whistleblower rewards only when the information provided by the whistleblower pertains to one or more of the following areas:

  • Violations by financial institutions, including money laundering, AML compliance, fraud and non-compliance with financial regulators;

  • Violations relating to foreign corruption and bribery

  • Violations related to payment of bribes or kickbacks to public officials

  • Violations related to federal health care fraud and related crimes involving health care benefit programs as well as fraud against patients, investors, and other non-governmental entities in the health care industry;

  • Violations related to fraud in connection with federally funded contracting or federal programs, where it does not involve health care or illegal health care kickbacks;

  • Violations related to sanctions offenses, material support of terrorism, or cartels and transnational criminal organizations;

  • Violations related to trade, tariff, and customs fraud

The DOJ Pilot Program addresses both criminal violations for conduct also captured by other whistleblower programs, including the False Claims Act, Dodd-Frank programs of the SEC and CFTC, and the FinCEN and IRS whistleblower programs, as well as conduct exclusively in the domain of criminal law enforcement by the Department of Justice.   

Who is Eligible to be a Whistleblower in the Pilot Program?

To be eligible for an award under the DOJ program, a whistleblower must meet several important criteria, in addition to providing information related to one of the enforcement areas listed above:

Original Information: An individual must provide original information to the government. Original information can come from a whistleblower inside the company or outside the company as long as it is derived from the whistleblower’s independent knowledge or independent analysis.

Qualified Subject Matter: The whistleblower’s information must be related broadly to violations involving financial institutions, foreign corruption, bribery, kickbacks, federal healthcare fraud, government contracting fraud, customs violations, or terrorism-related activities.

Voluntary, Complete and Truthful Disclosure: The individual must voluntarily submit full and truthful information.

Full Cooperation: The whistleblower must fully cooperate with the DOJ’s investigation and any resulting legal action, including court proceedings.

Successful Recovery: The government must recover through forfeiture more than $1 million in assets based on the whistleblower’s information for an award to be considered.

How Much Can a Whistleblower Receive?

Though the Department of Justice has discretion in determining the size of a reward, the general structure follows a tiered model:

  • Up to 30% of the first $100 million recovered as net proceeds through forfeiture.

  • Up to 5% of amounts recovered beyond $100 million (up to $500 million).

For example, if the government recovers $10 million based on a whistleblower’s tip, that whistleblower could potentially receive up to $3 million. The exact percentage awarded is based on the value of the information, the level of cooperation and the outcome of the case.

What are the Risks of Reporting Fraud Under the Pilot Program?

Becoming a whistleblower can involve personal, professional and legal risks. These may include:

  • Retaliation by an employer

  • Damage to your professional reputation

  • Legal exposure if you were involved in the misconduct

  • Emotional stress and uncertainty

If you are considering blowing the whistle, it’s critical to work with legal counsel experienced in whistleblower law, who will advise you on whether your information qualifies for protection and reward under the Department of Justice or other whistleblower program, how to make a protected disclosure and how to minimize your risks while preserving your right to an award.

Hagens Berman’s Whistleblower Practice

Our firm has helped numerous clients successfully navigate the complex world of whistleblower law through federal and state whistleblower reward programs including under the False Claims Act and the whistleblower programs of the SEC, CFTC, FinCEN (Financial Crimes Enforcement Network) and IRS whistleblower programs. Hagens Berman — among the largest and most successful plaintiff-side law firms in the world — has decades of experience filing and prosecuting cases on behalf of whistleblowers in qui tam litigation and has successfully represented dozens of Dodd-Frank whistleblowers with claims of securities fraud and commodities fraud. We will help you decide the best timing and method for disclosure to maximize your chances of receiving a reward and legal protection, and whether you may be able to make your disclosure without immediately revealing your identity.

Timing Matters

One of the most important aspects of the DOJ Corporate Whistleblower Awards Pilot Program is its emphasis on early voluntary reporting. If your company or another whistleblower comes forward first, you could lose eligibility.

Additionally, the DOJ encourages companies to disclose within 120 days of receiving an internal tip. That means employees who delay may find themselves shut out of the process — or even targeted as part of an investigation.

If you believe you have valuable information about misconduct that could fall under the DOJ’s pilot program, it’s in your best interest to act quickly and consult with counsel as soon as possible.

Contact Hagens Berman Today

The DOJ’s new Corporate Whistleblower Awards Pilot Program provides an unprecedented opportunity for individuals with knowledge of corporate fraud and other illegality to make a difference — and be rewarded for doing so.

If you have information about serious wrongdoing and are ready to take the first step, we invite you to contact our firm for a confidential consultation. We are committed to protecting whistleblowers, ensuring they are treated fairly and fighting for the justice they deserve.

We offer confidential, no-obligation consultations to assess whether you may qualify under the DOJ’s Pilot Program or one of the other federal whistleblower programs.

Confidential. Experienced. Trusted.

Frequently Asked Questions for Potential Corporate Whistleblowers

The Department of Justice Criminal Division’s Corporate Whistleblower Awards Pilot Program encourages individuals to report significant corporate or financial misconduct. This FAQ section provides answers to common questions about the program, including eligibility, the reporting process and potential awards. It is designed to help whistleblowers understand how the program works and what to expect after submitting information.

Am I eligible for an award if I provide information about an open investigation?

Yes, you may be eligible for an award if you submitted original information related to an open investigation after Aug. 1, 2024, and your tip contributed to a successful recovery. For example, if you provided new details about misconduct that leads to a recovery greater than $1 million, you may be eligible for a reward under the DOJ’s Corporate Whistleblower Awards Pilot Program.

Which Whistleblower Program Should I File Under? 

The DOJ’s Pilot Program is run by the Criminal Division’s Money Laundering and Asset Recovery Section (MLARS) and applies to specific types of fraud and other criminal conduct, some of which is covered under whistleblower laws regulated by the SEC, CFTC, IRS and under the False Claims Act. If after reviewing the information available here you are still unsure which program your claims may fall under, an experienced whistleblower attorney will be able to guide your filing process and ensure you file under the proper program. The DOJ Program has specific provisions that prevent an award where the information is also applicable under other whistleblower programs, so counsel should be consulted in making the decision about how best to use your information. 

Should I report to my company first?

No. Reporting internally may actually harm your ability to receive an award. While internal company “whistleblower” reporting tiplines are often branded to employees as an objective, helpful way to correct wrongs, often they are more nefarious. Reporting first internally may jeopardize your career, and information you report could be used against you should you take your claim to federal whistleblower programs. Whistleblowers are best suited to retain professional help through whistleblower lawyers to assist them in bringing their claims to federal agencies to help maximize both the usefulness of their information and their protections against retaliation.

Do I need a lawyer?

Submitting your information with the help of a whistleblower attorney is the only way to submit anonymously and can make all the difference if the right counsel is selected. It is highly recommended that whistleblowers protect themselves in this way when reporting fraud. An experienced attorney will be invaluable in presenting your information effectively and guiding you through the process. The reputation of counsel also helps distinguish between your submission and the thousands of others made each year. 

When can I expect payment?

Determining whether whistleblowers are eligible for payment takes time. Federal prosecutors must review your information, conduct investigations, gather evidence, assess the potential for criminal prosecution, seize and officially forfeit assets, and complete the forfeiture process — which may not conclude until all appeals are resolved. After that, the Department of Justice will decide, at its discretion, whether the whistleblower qualifies for an award. This process typically takes at least a few years.