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DOJ Adds Federal Immigration Violations to Corporate Whistleblower Awards Pilot Program
Tuesday, June 3, 2025

As of May 12, 2025, whistleblowers may receive a financial award in exchange for emailing the Criminal Division of the Department of Justice (DOJ) to provide information about potential corporate immigration violations. The Biden administration created the Corporate Whistleblower Awards Pilot Program in August 2024. The program provides a financial incentive for whistleblowers to report their current and/or former employers’ possible misconduct. If the whistleblower’s tip results in a successful forfeiture, then, if eligible, the whistleblower may be entitled to a percentage.

The original program focused on four different areas of corporate misconduct: (1) crimes involving financial institutions; (2) foreign corruption; (3) domestic corruption; and (4) health care fraud. Now, as part of its new white collar crime enforcement initiative called “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” the DOJ amended its Corporate Whistleblower Awards Pilot Program to include “violations by corporations of federal immigration law.”

The program includes a corporate enforcement and voluntary disclosure policy, which provides employers with a 120-day safe harbor to investigate, remediate, and self-disclose violations. Under this provision, companies that voluntarily self-report within 120 days of receiving an internal whistleblower report may be eligible to receive a declination of prosecution from DOJ. The inclusion of federal immigration law violations in the DOJ’s Corporate Whistleblower Awards Pilot Program emphasizes the administration’s focus on immigration compliance. Employers should take steps to enhance their internal reporting process, and also consider auditing their immigration compliance programs, from their I-9 and E-Verify practices to their visa and green card sponsorship programs. Employers should also confirm their relevant employees are trained and up to date with the updates and changes in this area.

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