How to Report Antitrust Violations: Prepare for a Confidential Case Review

Whistleblower Justice Network

To decide how to report antitrust violations, start with our whistleblower experts for an antitrust whistleblower case review. You may know who supplied a supposedly competing quote, why a sales team stopped pursuing a customer or who told recruiters to leave a rival’s employees alone. We connect that account to the bids, prices and hiring decisions it affected, then assess the whistleblower case with you.

The important detail may sit in an ordinary part of your job. An estimator knows which bid was meant to lose. A recruiter knows where an instruction came from. Someone managing auction accounts knows who could see another bidder’s confidential information. That knowledge can explain the agreement behind the transaction.

What Can Help the Antitrust Division Understand My Report?

A useful antitrust report connects the companies involved, what they agreed to do and how that agreement affected competition. Our case review puts those facts in the context of the business you know.

We work through a few concrete questions with you:

  • Your role and knowledge. What did you see, hear or do yourself? What did someone else tell you, and what have you inferred from the pattern?
  • The agreement. Which companies communicated, through which roles, about which bids, prices, customers or workers?
  • What changed. Which offer, discount, customer assignment or hiring decision followed the communication?
  • The supporting records. What does each document show, who created it and when, and where is the original held?

An email about a price change means more when it connects to the quote the customer received. A customer list means more when someone can explain why sales staff were told to leave those accounts alone. We distinguish the records you have from those you know exist, and examine the surrounding communications and any facts that point another way.

Prior internal or government reports, requests for documents and your own involvement belong in that conversation too. Questions about confidentiality, access to records or participation in the conduct are matters we address with you and antitrust whistleblower counsel.

Who Should Report Bid Rigging, a Procurement Officer, Vendor or Employee?

A procurement officer, vendor or employee may each know something that exposes bid rigging. Purchasing staff see the offers presented as competitors. The vendor’s estimator may know who wrote them. An employee may know why a bid was raised, withdrawn or never submitted. Customers and affected competitors can also bring information forward.

Procurement Staff See Whether the Quotes Compete

The source of a quote can matter as much as its price. Berg Companies’ military-shelter business illustrates why. A prime vendor buying through the Defense Logistics Agency’s maintenance, repair and operations program had to obtain independently competing quotes. In its civil settlement announcement, the Justice Department said Berg admitted coordinating and submitting inflated quotes.

The department alleged that those quotes helped designated sub-vendors win shelter orders. The military was supposed to get independent prices. Berg agreed to a $3.3 million False Claims Act settlement over those shelter purchases.

For someone inside that purchasing chain, the useful connection is between the quote request, the person who supplied the competing figure and the vendor ultimately selected. Who actually priced the shelter? Who revised the offer? Which business got paid?

Bid Staff Know Which Offer Was Supposed to Lose

Government fuel procurement shows how an agreement can reach individual line items. In its civil complaint against GS Caltex, Hanjin Transportation and SK Energy, the United States alleged that suppliers divided military fuel business in South Korea and agreed to submit high bids or withhold bids on work allocated to another supplier.

The complaint describes what allegedly happened when the bidding produced an unwanted winner:

Companies B and C accidentally won one line item that the conspiracy had allocated to GS Caltex. To remedy this misallocation, Company B and GS Caltex agreed that GS Caltex, rather than Company C, would supply Company B with the fuel procured under this line item.

United States of America v. GS Caltex Corporation, Hanjin Transportation Co., Ltd., and SK Energy Co., Ltd., complaint, paragraph 24.

The suppliers allegedly treated an unexpected win as a mistake to be corrected, even after the military had awarded the work. A procurement officer might see the award. A supplier’s employee might know why the fuel came from a different company. Bid versions, line-item allocations and supply instructions connect those parts.

Sales Staff See the Price Behind the Announcement

Price fixing can reach discounts and promotions as well as a published list price. The government’s court brief in the criminal tuna price-fixing case described coordination over both list-price increases and promotional net prices.

For a salesperson, the relevant history may be a competitor communication followed by a change in promotional approval. The list-price announcement and the price actually offered to the customer capture different parts of that decision.

Customer allocation has its own records: account lists, instructions not to quote and the communications explaining which rival was to get the business. The product, customer and timing give the agreement its meaning.

Staffing Employees See the Hiring Decision

Wage fixing and no-poach agreements can appear in recruiter instructions, employer-to-employer emails and payroll decisions. In its criminal guilty plea, health care staffing company VDA OC admitted a wage-fixing and no-poach agreement with a rival involving nurses serving the Clark County School District.

An employee may know who passed along the restriction and which jobs it affected. Recruiting records, staffing assignments and wage decisions can connect the agreement to its operation. Actual hires, transfers and exceptions can show how staff applied the restriction.

Technical Staff See How Coordination Became a Setting

For software and platform employees, an instruction can become a permission, a pricing input or a change in code. Bid histories, account access and pricing settings can help explain how people implemented an agreement.

The Justice Department’s competitive impact statement in its civil case against RealPage describes allegations that competitors’ nonpublic rental information and pricing recommendations reduced independent price competition. Someone familiar with a pricing system may know which information entered it, who supplied it and how recommendations reached the people setting prices.

How Is Bid Rigging Detected?

Bid rigging can come to light through an insider’s account, a customer’s complaint or analysis of purchasing data. The strongest case review connects the pattern in the bids to the people and communications that explain it.

The Department of Justice’s procurement guide identifies repeated winners, rotating awards, identical errors in competing bids and losing bidders receiving subcontracts as signs worth examining. A procurement employee may recognize that a familiar competitor keeps bidding high on the same work. A vendor employee may know the instruction behind those bids.

The 2018 construction-bidding review describes price uniformity and stable market shares among the indicators used to identify markets for closer examination. An insider’s account can connect those patterns to the people and decisions behind the bids.

Which Reporting Route Fits the Facts?

The reporting route depends on the conduct, the information you have and who paid for the affected business. We assess those connections with you, including whether the evidence supports an antitrust whistleblower reward or a False Claims Act case involving government money.

What Is the Antitrust Whistleblower Rewards Program?

The Antitrust Whistleblower Rewards Program can pay individuals whose information leads to a qualifying criminal recovery. Its governing agreement covers criminal Sherman Act violations and certain federal crimes involving public procurement, competition investigations or conduct that facilitates or conceals an antitrust violation.

Where the Justice Department determines a reward is appropriate, the presumptive total award range is 15% to 30% of the qualifying recovered money. Eligible whistleblowers share that total.

We assess whether your information and the postal connection qualify with antitrust whistleblower counsel. The auction case below shows why the relevant business can be a private market.

Government Purchases Can Support a False Claims Act Case

When coordinated bids produce false claims for government payment, the False Claims Act can provide a whistleblower route. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

Sea Star Line and Horizon Lines agreed to a $3.4 million civil settlement over allegations that they fixed government cargo transportation prices between the continental United States and Puerto Rico. The government alleged that former executives exchanged confidential bid information through personal email accounts, allowing the shippers to allocate routes at predetermined rates. The affected work included Postal Service mail and Department of Agriculture food shipments. Taxpayers paid for cargo routes the shippers allegedly divided among themselves.

A former Sea Star executive brought the whistleblower case, and the government joined it. The transaction supplied the connection: confidential rates, allocated routes and government-paid cargo.

What Happens After Submitting Antitrust Evidence to DOJ?

After receiving antitrust evidence, the Justice Department reviews the account and its supporting information. We help you and antitrust whistleblower counsel respond to questions about the transactions and the records behind them.

An email, a bid table and a witness may each explain a different part of the same transaction. Our work with you continues through interpreting that evidence and cooperation with investigators.

If you have already reported internally or contacted an agency, we assess that history with you. Anonymity, retaliation, leniency and your own part in the conduct are questions for that individual review with us and antitrust whistleblower counsel.

The Postal Connection in the First Antitrust Whistleblower Reward

The first announced reward under the Antitrust Whistleblower Rewards Program arose from EBLOCK’s private used-car auction business. The Justice Department and the Postal Service announced a $1 million whistleblower payment on January 29, 2026.

Under its deferred prosecution agreement in the criminal case, EBLOCK accepted responsibility for conduct at an acquired auction business. Employees coordinated maximum bids with another company bidding in the auctions and gave it access to confidential bidding information. They pooled inventory and profits. Shill-bidding software also generated sham bids using real dealerships’ names without their consent.

The admitted conduct continued after the acquisition. The agreement describes employees concealing its continuation and EBLOCK eventually refusing to carry the shill-bidding functionality into a platform migration.

The reward announcement identified documents mailed in support of the scheme. The auction’s customers were used-vehicle buyers.

For a platform employee, account permissions, bidding records, software changes and profit records are concrete places where an agreement may leave evidence.

Your Antitrust Whistleblower Case Review

If you know why a competitor’s quote, a recruiting decision or an auction bid was arranged in advance, speak with our whistleblower experts for a confidential case review. We build the strategy around what you can show and bring in antitrust whistleblower lawyers who know bid-rigging, price-fixing and no-poach cases. We stay with you throughout, building your strongest antitrust whistleblower case and pursuing your share of a recovery.

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