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Some Thoughts on the Antitrust Division’s New Whistleblower Reward Program

 |  July 21, 2025

By: Robert Connolly (Cartel Capers)

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    In this new post for Cartel Capers, author Robert Connolly (Cartel Capers) shares his insight on the U.S. Department of Justice Antitrust Division’s newly announced Whistleblower Rewards Program, launched on July 8, 2025. While the initiative has been widely praised and has generated numerous legal commentaries, Connolly adds his own view, calling it a positive step forward. The program offers potential monetary rewards—up to 30% of criminal fines recovered—for individuals who report antitrust violations affecting the U.S. Postal Service (USPS), though what qualifies as such a violation remains murky.

    Connolly explores how narrowly or broadly the language in the program could be interpreted. A narrow reading would limit rewards to cases where vendors collude on USPS-issued bids or contracts, while a broad reading might include nearly any antitrust violation that merely involves USPS infrastructure, like using the mail to facilitate fraud. He notes that the USPS already has a whistleblower mechanism through the False Claims Act, making it unclear how distinct this new program truly is. The ambiguity leaves potential whistleblowers and their attorneys uncertain about what exactly qualifies for a reward.

    Referencing the program’s Memorandum of Understanding (MOU), Connolly points out that eligibility is determined based on whether a whistleblower can reasonably articulate a USPS-related legal violation with supporting facts. Interestingly, the MOU says that the harm to the Postal Service “need not be material,” which sets a low bar for triggering review. Still, despite encouraging language from the DOJ suggesting broader eligibility—including harm to consumers and competition—Connolly concludes that the true reach and impact of the program remain unclear. Only time and real-world experience will define its practical scope…

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