Top 5 Whistleblower Program Developments for 2025

By the Constantine Cannon Whistleblower Team

Last year was a notable year for whistleblowers across the many whistleblower programs that reward insiders for reporting fraud and misconduct to the Government.  The False Claims Act saw the most action, as usual, with a record number of whistleblower filings and recoveries.  This is the statute that allows individuals to bring lawsuits on behalf of the Government against those committing fraud against the Government, and to share in any resulting recovery.  It is by far the most prolific rewards program for whistleblowers.

But three other programs also received some serious attention in 2025.  One was the Antitrust Whistleblower Rewards Program that the Department of Justice (DOJ) launched in July and for which it issued its first award only six months later.  Another was the Corporate Whistleblower Awards Pilot Program, which DOJ launched in 2024 and significantly expanded last May to cover a much broader swath of potentially criminal activity.  And finally was the IRS Whistleblower Program, which last April went through a major revamping to better protect and serve whistleblowers and reward them for their efforts.

All this is a testament to the clear recognition at the highest levels of Government that whistleblowers play a critical role in protecting all of us from fraud and misbehavior.  It also demonstrates the widespread support for providing financial incentives for whistleblowers to come forward, not only because of the valuable role they serve, but also because of the significant risk they take and sacrifice they make in reporting illegal activity.

With all that said, here is our Top 5 listing of key whistleblower program developments for 2025:

No. 1 – Record Year for False Claims Act Recoveries

For its fiscal year ending September 30, 2025, DOJ recovered roughly $6.9 billion under the False Claims Act, the largest single-year haul ever under the statute.  Almost 80% of that amount — or $5.3 billion — came from actions originated by whistleblowers under the qui tam provisions of the statute.  And of these whistleblower-prompted recoveries, $2.3 billion came from False Claims Act cases whistleblowers pursued on their own, without Government support.  This past year was also a record year for whistleblower filings, with whistleblowers filing 1,297 qui tam lawsuits, more than three times the 401 cases the Government filed, and far surpassing the prior record of 980 qui tam suits whistleblowers filed in 2024.  Notably, 9 of the Top 10 whistleblower awards for 2025 went to whistleblowers under the False Claims Act, a marked departure from prior years.

No. 2 – Record False Claims Act Customs Fraud Recovery

On December 18, DOJ announced that North Carolina-based Ceratizit USA agreed to pay $54.4 million to settle allegations it violated the False Claims Act by failing to pay customs duties on the products it imported from China.  It was just one of a string of customs fraud settlements in 2025, but the largest ever under the statute.  It also was another powerful indication the Trump Administration considers customs fraud a top enforcement priority.  In addition to the many False Claims Act settlements last year, DOJ launched a customs fraud task force in August, partnering with Homeland Security to “aggressively pursue” customs scofflaws and smugglers.  And in May, DOJ expanded its Corporate Whistleblower Awards Pilot Program (discussed below) to cover customs fraud.

No. 3 – Launch of Antitrust Whistleblower Award Program

On July 8, the DOJ Antitrust Division launched the Antitrust Whistleblower Rewards Program to reward individuals who report antitrust crimes and related offenses.  It is the first rewards program specifically targeting antitrust whistleblowers and followed years of failed efforts in Congress to pass any kind of antitrust whistleblower legislation.  In announcing the program, then DOJ Antitrust Chief Abigail Slater stressed the critical role the Antitrust Division hopes whistleblowers will play: “If you’re fixing prices or rigging bids, don’t assume your scheme is safe — we will find and prosecute you, and someone you know may get a reward for helping us do it.”  Notably, DOJ issued its first award under the program in February, only 6 months after the program commenced, a record under all the many whistleblower rewards programs, some of which have been in place for years and have yet to issue their first award.

No. 4 – Expansion of DOJ Corporate Whistleblower Rewards Pilot Program

In August 2024, DOJ launched its Corporate Whistleblower Awards Pilot Program to focus on criminal activity falling outside the already established False Claims Act, SEC, CFTC, FinCEN, and IRS whistleblower programs.  The primary areas of corporate crime the program originally targeted were foreign and domestic corruption, financial institution fraud, and healthcare fraud.  In May 2025, DOJ expanded the program to also target: (i) government contracting fraud, (ii) tariff and customs fraud, (iii) immigration law violations, and (iv) illicit activity by international cartels relating to sanctions offenses, money laundering, drug trafficking, and terrorism.  In announcing the expanded program, then DOJ Criminal Chief Matthew Galeotti made clear the agency’s strong support for whistleblowers: “We want to hear from you and we want your companies to hear from you.  Now is the time to report, remediate, and strengthen compliance to ensure American prosperity.”

No. 5 – IRS Plan to Advance Its Whistleblower Program

On April 18, the IRS Whistleblower Office announced its first ever multi-year operating plan to expand the reach, visibility, and impact of its Whistleblower Program, which to date has made more than $1.3 billion in awards since the program launched in 2006.  Among the core priorities of the new IRS plan are enhancing the whistleblower claim submission process, rewarding whistleblowers fairly and quickly, providing greater transparency to whistleblowers, and safeguarding whistleblower information.  Notably, the IRS award to the Credit Suisse whistleblowers who helped the agency secure a $510 million settlement from the company in May 2025 took the top spot in our Top 10 list of whistleblower awards for 2025.

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Constantine Cannon whistleblower partner Gordon Schnell pointed to these developments as a powerful demonstration of how highly the Government values whistleblowers and how serious the Government has become in greasing the available channels for whistleblowers to report fraud.  Schnell says, “We are seeing an ever-increasing number of whistleblower rewards programs, the Government taking steps to strengthen those that already exist, and these programs reaching new whistleblower milestones on a regular basis.”

Schnell expects this trend to continue “not only because of how successful these programs have been in helping the Government police bad behavior, but also because of the significant resource constraints so many agencies are currently facing.”  According to Schnell, “Whistleblowers are only becoming more and more important, a fact the Government has increasingly come to appreciate.”

Constantine Cannon has substantial experience representing whistleblowers under the False Claims Act and the many other whistleblower rewards programs, with several record-breaking successes.  In total, our representations have led to more than $1 billion in Government and whistleblower recoveries.  This is in addition to the roughly $10 billion we have recovered for the firm’s other clients, including three of the top five antitrust settlements in U.S. history.

If you would like to learn more about our work, the various whistleblower rewards programs, or what it means to be a whistleblower more broadly, please do not hesitate to contact us.  We will connect you with an experienced member of our whistleblower team for a free and confidential consultation.

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