When the DOJ Antitrust Division launched its first whistleblower reward program (AWB Program) in July 2025, it created a powerful incentive for employees and third parties to report potential antitrust crimes directly to the government. In this guest article, Pillsbury partner Mark Krotoski and attorney Vinny Sidhu explain the mechanics of the AWB Program and how it interacts with other whistleblower reward programs, highlight how companies should reassess the structure and function of their internal reporting systems, and provide a framework for how companies should think about self-reporting possible antitrust issues because of the AWB Program. See our two-part series on the DOJ’s Corporate Whistleblower Awards Pilot Program: “A Look at Forfeiture and Culpability” (Aug. 14, 2024), and “Exclusions, NDAs and Goals” (Sep. 11, 2024).
