(UNITED STATES) The U.S. Department of Justice (DOJ) has expanded its Corporate Whistleblower Awards Pilot Program to include corporate violations of federal immigration law, a move that took effect immediately on May 12, 2025. Announced by DOJ Criminal Division head Matthew R. Galeotti at the SIFMA Anti-Money Laundering and Financial Crimes Conference, the change signals a sharp rise in federal attention on visa fraud, unauthorized hiring, and false statements in immigration filings.
Under the expanded program, whistleblowers whose tips lead to a qualifying forfeiture may receive awards of up to 30% of recovered assets, creating strong incentives to report corporate misconduct tied to immigration.
Program scope and policy context
The expansion places immigration-related corporate misconduct alongside financial crimes, corruption, and health care fraud within the same whistleblower framework. It aligns with the Trump administration’s broader crackdown on corporate immigration violations, including increased DOJ and FBI scrutiny and more workplace enforcement actions.
At the same time, the DOJ maintains a pathway for companies to avoid prosecution if they act quickly and remediate problems. The dual message is clear: report wrongdoing early or risk major penalties.
Launched in August 2024 under President Biden to focus on white-collar offenses, the Corporate Whistleblower Awards Pilot Program is now pointed squarely at corporate misuse of employment-based visa programs (including H-1B practices), hiring of unauthorized workers, and falsified information on visa petitions. DOJ officials describe immigration fraud as a tip-eligible area for whistleblower awards, aligning the program’s financial incentives with enforcement priorities.
Key elements of the DOJ expansion
- Eligible violations: “Violations by corporations of federal immigration law,” including misuse of visa programs, unauthorized employment, and false statements in visa-related filings.
- Whistleblower eligibility: Any individual — including current or former employees — who provides original, truthful information that leads to a successful criminal or civil forfeiture.
- Award potential: Up to 30% of forfeited assets if the case results in a forfeiture of at least $1,000,000.
- Confidential submissions: DOJ treats submissions as confidential to the fullest extent allowed by law.
- Reporting channels: Tips can be submitted via the DOJ intake process or by emailing [email protected].
- Anti-retaliation stance: DOJ will weigh retaliation or interference against whistleblowers when assessing a company’s cooperation and may penalize companies that punish reporters.
The DOJ’s formal program page provides core details and contact information for potential whistleblowers and companies seeking guidance: https://www.justice.gov/criminal/criminal-division-corporate-whistleblower-awards-pilot-program. According to analysis by VisaVerge.com, the inclusion of immigration-related conduct fills a gap left by earlier False Claims Act efforts that struggled to capture visa petition misconduct.
Employer risks and safe harbor
The most immediate impact on employers is higher liability risk. The program invites employees, contractors, and others to bring original, non-public information to the DOJ, increasing the chance a tip will trigger inquiries into a company’s hiring systems, document practices, and use of foreign worker programs.
DOJ has set a clear safe harbor tied to its Corporate Enforcement and Voluntary Self-Disclosure Policy:
- If a company receives an internal report of immigration-related misconduct and self-discloses to DOJ within 120 days, remediates promptly, and cooperates, the department may apply a presumption of declination (i.e., it will not prosecute).
- This safe harbor is not automatic; it depends on quick action, strong internal controls, and good-faith remediation.
- Companies that retaliate against whistleblowers risk losing cooperation credit and facing added penalties.
Legal and compliance advisors urge employers to take immediate steps that are simple but effective:
- Strengthen internal reporting channels and train managers to escalate tips.
- Investigate complaints quickly and document all steps.
- Review I-9 and visa compliance procedures and fix gaps.
- Enforce anti-retaliation rules and communicate them clearly.
For many employers, the Form I-9 process is the first line of defense. HR teams should ensure every new hire’s identity and work authorization are verified using Form I-9 and that records are kept properly. The official Form I-9 resource is available at: https://www.uscis.gov/i-9. In audits, inconsistent I-9 records can expose broader risks, including patterns of unauthorized employment or document issues that attract federal attention.
Enforcement priorities under the expansion
- Misuse in employment-based visa programs, including H-1B-related practices
- Unauthorized hiring and continued employment after loss of work authorization
- False statements or document fraud in support of visa petitions
DOJ and the FBI are prioritizing industries that employ large numbers of non-citizen workers, where tips can surface systemic issues. As of August 14, 2025, DOJ has reported a rise in immigration-related tips since the expansion, though no public prosecutions under the revised program have been announced.
How whistleblowers report and what happens next
Individuals who have first-hand, non-public information about a corporation’s immigration violations can follow these steps:
- Gather original records or facts that show the suspected violation.
- Complete the DOJ’s whistleblower intake materials as directed on the program page.
- Email the submission and supporting documents to [email protected].
- If DOJ pursues the case and secures a qualifying forfeiture of $1,000,000 or more, the whistleblower may be eligible for up to 30% of that amount.
Confidentiality applies to the fullest extent of the law, and DOJ tracks whether companies try to block or punish whistleblowers. Retaliation can reduce a company’s cooperation credit or lead to separate consequences. For workers who fear reprisals, this protection is meaningful: the program seeks to protect the flow of accurate information to federal investigators.
Implications for companies, boards, and investors
For companies, the policy pressures leadership to invest in compliance. Practical steps include:
- Updating policies and auditing high-risk business units.
- Training HR, legal, and recruiting teams on immigration rules.
- Rehearsing rapid response: assign roles for receiving internal reports, preserving evidence, conducting privileged investigations, and making timely self-disclosures when warranted.
The policy shift also affects how boards and investors view risk. Immigration exposure now sits in the same bucket as accounting fraud or anti-corruption failures. Directors and audit committees will expect clear reporting on:
- I-9 trends and accuracy
- Visa program usage and related practices
- Third-party recruiters and any internal complaints tied to immigration practices
Insurers may also ask more questions about internal controls and disclosures.
Broader context and outlook
The pilot program’s 2024 launch under President Biden focused on white-collar crime. In May 2025, President Trump’s DOJ added immigration violations, reflecting a change in priorities and tactics.
Previous efforts to use the False Claims Act for visa petition issues often stalled because petitions aren’t easily treated as “claims” for payment. The Corporate Whistleblower Awards Pilot Program avoids that roadblock by tying awards to forfeiture, not FCA recoveries.
Looking ahead:
- DOJ may refine or expand the initiative based on results and feedback.
- Employers should assume continued scrutiny and a steady stream of tips.
- Workers have clearer paths to report — and potentially to be rewarded — for exposing misconduct.
- Companies that move fast when they receive an internal report, fix the issues, and protect the whistleblower stand the best chance of avoiding prosecution while maintaining lawful hiring systems.
Key takeaway: Protect internal reporting channels, verify and document I-9 and visa compliance, and consider prompt self-disclosure if misconduct is identified — otherwise, whistleblower tips tied to immigration violations may trigger significant enforcement and potential forfeitures.
This Article in a Nutshell
On May 12, 2025, DOJ added corporate immigration violations to its whistleblower pilot, rewarding tips that lead to $1,000,000+ forfeitures with up to 30% payouts.
