Cross-Border Cartel Reporting: U.S. Rewards, Foreign Leniency and Confidentiality

International cartel whistleblower leniency and rewards serve different purposes: leniency concerns a participant’s cooperation, while a reward pays an eligible person for information. Cross-border cartel reporting puts those differences into focus. You may work overseas, know which rival received the winning contract, and hold the messages explaining why everyone else bid to lose. The company’s disclosure, your information and the government’s purchases each deserve their own examination. Our whistleblower experts work with you to build a case from what you know.

What Is the Antitrust Whistleblower Rewards Program?

The Antitrust Whistleblower Rewards Program can pay eligible individuals who voluntarily provide original information about criminal antitrust conduct and related offenses. The Justice Department launched it with the Postal Service in 2025.

The program’s governing agreement requires at least $1 million in a qualifying criminal recovery and identifiable harm to the Postal Service. The presumptive total reward is 15% to 30% of qualifying money recovered, shared among eligible whistleblowers when there is more than one.

Covered conduct includes price fixing, bid rigging and market allocation, along with specified crimes affecting public procurement or competition investigations.

For a foreign employee reporting a U.S. cartel, reward eligibility calls for an examination of the conduct, the information and the connection to the United States. Original information can include firsthand business communications and observations, or independent analysis of data. We assess those facts with you, including any government purchases or use of the mail connected to the scheme.

The Postal Connection Can Sit in an Ordinary Transaction

The EBLOCK payment was a $1 million U.S. antitrust-program award, separate from foreign leniency or reward arrangements.

The EBLOCK example links auction activity with the transaction records relevant to the U.S. reporting route. The department’s announcement identified documents sent through U.S. Mail in support of the scheme.

The auction appeared to put buyers in competition. Behind it, participants shared information and the proceeds. The platform’s permissions and bidding records explained the arrangement, while the mailed documents supplied a separate part of the story.

Will My Confidentiality Be Protected?

Your confidentiality deserves a conversation about your circumstances from the start. Our whistleblower experts and antitrust whistleblower lawyers work through anonymity and consent to foreign disclosure with you as part of building your case.

What Is the Leniency Program for Individuals and Corporations Involved in Criminal Antitrust Activity?

For an international cartel, we assess what the U.S. leniency program means for your circumstances and the information you can contribute. The individual reward program pays for useful original information. An employer’s leniency application and an employee’s reward opportunity therefore call for separate attention.

For questions about foreign leniency and U.S. reporting, our whistleblower experts bring in antitrust whistleblower lawyers with the relevant experience.

For a cartel operating across countries, we work through the relevant authorities and programs with you.

If your employer has announced a disclosure, or you took part in the conduct you want to report, we work through that position with you. The useful starting point is what you actually know: the conversations, the instructions and how the agreement between competitors worked in practice.

European and UK Cartel Reporting Use Different Programs

European cartel reporting involves separate Commission and national programs. What a company receives for cooperating differs from what an individual can receive for information.

We assess the European Commission’s leniency framework with you in light of the company’s conduct and your own position.

The UK’s Competition and Markets Authority has a separate cash reward policy for people with useful cartel information. On June 6, 2023, it announced an increase in the maximum discretionary reward to £250,000. Its reward policy considers the value of the information and the whistleblower’s contribution.

We examine the relevant countries and programs together with you. An employee explaining what happened inside the business has a different position from a company negotiating over its own conduct. Keeping that distinction clear is the beginning of a useful cross-border assessment.

U.S. Government Purchasing Reaches Overseas Contracts

Government purchasing can connect an overseas cartel to U.S. enforcement. In its filed guilty plea agreement, G4S Secure Solutions NV admitted to allocation and bid coordination for security services in Belgium, including U.S. defense-related contracts.

The security work occurred in Belgium. The U.S. government was among the customers whose contracts the arrangement covered. For someone who knows how a foreign contract was awarded, the purchaser and the competing bids can be as significant as the location of the work.

That commercial connection also matters to the False Claims Act. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. When collusion produces false claims for government payment, we examine the bids and payments alongside the cartel agreement to assess that opportunity.

Shipping Rates Fixed Around Government Cargo

Sea Star Line and Horizon Lines show how that connection can work. In its March 2014 civil settlement announcement, the Justice Department alleged that former executives shared confidential government bidding information through personal email accounts. That exchange enabled them to allocate routes at predetermined rates. The cargo included Postal Service mail and Agriculture Department food shipments.

Taxpayers were paying for mail and food shipments. According to the government’s allegations, the carriers had already divided the routes and settled the rates. The bidding emails connected the alleged agreement between rivals to what the government paid.

Sea Star agreed to pay $1.9 million and Horizon agreed to pay $1.5 million in separate False Claims Act settlements. A former Sea Star executive brought the whistleblower case and received a share of the recovery.

Military Fuel and a Whistleblower in South Korea

The Korean military-fuel cases make the overseas reporting connection more direct. Hanjin Transportation’s False Claims Act settlement agreement identifies the whistleblower as a South Korean citizen and resident.

In the government’s civil complaint against GS Caltex, Hanjin and SK Energy, the alleged arrangement involved allocating fuel-contract line items and coordinating losing bids or decisions not to bid.

The GS Caltex complaint account compared margins on U.S. military fuel with sales to South Korean military and private customers, showing how the alleged foreign arrangement reached U.S. taxpayers.

The complaint also alleged that companies accidentally won a fuel line item assigned to GS Caltex. A rival and GS Caltex then changed the supply arrangement so GS Caltex supplied that fuel. The contract award and the supply arrangement told different parts of the story. For a logistics or purchasing employee, the change in supplier could explain how rivals honored their allocation even when the bidding result went wrong.

The government alleged that American taxpayers paid inflated fuel prices while the suppliers earned higher margins. Someone inside pricing, supply or transportation could understand those contracts in a way a reader of the bid results alone could not. We connect that business knowledge to the alleged agreement and the government payments it affected.

What Can Help the Antitrust Division Understand My Report?

The companies, the products or services, the communications and the effect on competition give a cartel report its substance. In a cross-border matter, we connect those facts to the customers and countries involved. The decisive information may explain who chose the winner, why a rival held back, or how the companies shared the benefit afterward.

Different authorities may learn of a cartel through reports or their own inquiries; the investigation-process page explains those methods.

The cases show why that knowledge matters. EBLOCK admitted that participants had access to rivals’ bids. In the shipping case, the government alleged that personal emails carried confidential bidding information. In the fuel complaint, it alleged that rivals used meetings, calls and emails to divide contract line items. We work with you on the connection between the business decision and the evidence behind it.

Your Knowledge Can Connect the Countries

Tell our whistleblower experts where the agreement operated and which transactions reached the United States; we bring in whistleblower lawyers for the cross-border reporting questions.