When DOJ officials first announced that they would be launching a whistleblower reward program in March 2024, they laid out the basic outlines of what the program could include but left the details for a 90‑day policy-drafting sprint. Now that the DOJ’s Corporate Whistleblower Awards Pilot Program (WAPP) is in effect, the particulars of the program are clearer – and somewhat surprising. In the first part of this two-article series, we discussed the WAPP’s limited applicability and how it differs from Deputy Attorney General Lisa Monaco’s rhetoric last March. This second part examines some of the specifics of who is and is not eligible for an award, how the program encourages strong speak-up cultures at companies and the DOJ’s focus on companies that might impede whistleblowing through non-disclosure agreements. See “Whistleblower Protection and Compliance: A Comparative Study of the United States and Japan” (Jul. 31, 2024).