In this article, James Tillen and Daniel Patrick Wendt discuss the Department of Justice's (DOJ) plans to launch a pilot program that would reward whistleblowers at unlisted U.S. companies. "The SEC program provides payments from resolutions, and therefore may be an important model for the DOJ to consider while designing the detailed operation," Wendt explained. "The DOJ appears to be encouraging a race between corporations and their employees to report violations to the DOJ with only one winner possible," Tillen said. This article is the second is a series on the DOJ pilot program in The Anti-Corruption Report. Comments from the authors in the first article can be found here.