On May 12, the Head of the Department of Justice’s Criminal Division, Matthew R. Galeotti, announced that the DOJ Whistleblower Program has added a number of priority areas for tips which align with current administration’s priorities.

According to Galeotti, the new priority areas are

• “procurement and federal program fraud; 
• trade, tariff, and customs fraud;
• violations of federal immigration law; and
• violations involving sanctions, material support of foreign terrorist organizations, or those that facilitate cartels and TCOs, including money laundering, narcotics, and Controlled Substances Act violations.”

These areas were added to the official revised guidelines for the Department of Justice Corporate Whistleblower Awards Pilot Program.

“We have made changes to our corporate whistleblower program to reflect our focus on the worst actors and most egregious crimes,” Galeotti stated.

The DOJ Whistleblower Program was established in August 2024. While the program’s framework falls critically short of some proven best practices for whistleblower programs, it offers monetary awards to insiders who provide original information which lead to successful forfeitures. 

When the DOJ announced its plans for the whistleblower program, then-Deputy Attorney General Lisa Monaco stated the program “would fill the gaps in [the] patchwork” of successful corporate whistleblower programs, such as those administered by the SEC, IRS and FinCEN.

The original subject areas of the DOJ Whistleblower Program, which remain in the revised framework, are: 

• “Violations by financial institutions, their insiders, or agents, including schemes involving money laundering, anti-money laundering compliance violations, registration of money transmitting businesses, and fraud statutes, and fraud against or non-compliance with financial institution regulators.
• Violations related to foreign corruption and bribery by, through, or related to companies, including violations of the Foreign Corrupt Practices Act, violations of the Foreign Extortion Prevention Act, and violations of the money laundering statutes.
• Violations committed by or through companies related to the payment of bribes or kickbacks to domestic public officials, including but not limited to federal, state, territorial, or local elected or appointed officials and officers or employees of any government department or agency.
• Violations committed by or through companies related to (a) federal health care offenses and related crimes involving health care benefit programs, and (b) fraud against patients, investors, and other non-governmental entities in the health care industry.”

Notably, a wide range of misconduct which fall under the DOJ Whistleblower Program’s new priorities are covered under existing whistleblower programs. For example, government procurement fraud and trade, tariff, and customs fraud are covered by the False Claims Act, which is handled by the DOJ Civil Division (though related criminal actions can be taken). Sanctions evasion is covered under FinCEN’s AML and Sanctions Whistleblower Program.

Geoff Schweller also contributed to this article.