The U.S. Department of Justice (DOJ) on Monday announced a new pilot program to reward citizens who blow the whistle on fraud with up-front payments. The program supplements existing programs that reward whistleblowers after litigation concludes. On Monday, President Donald Trump presented what appears to be the first award from the program, a $10,000 check to citizen journalist Nick Shirley.

The DOJ described the Fraud Whistleblower Incentive Program (WHIP) — not to be confused with the White House Internship Program (also WHIP) — as “the first ever whistleblower rewards program that pays an up-front award for tips leading to criminal charges.”

“While most existing Government whistleblower rewards programs issue awards only after the final resolution of a criminal matter, including the forfeiture and appeals process, the Fraud Whistleblower Incentive Program (WHIP) rewards whistleblowers at a much earlier stage of prosecution,” it stated in a press release.

Under the False Claims Act, some whistleblowers can receive up to 25% or 30% of the recovered funds. However, they only receive the funds after a conviction is obtained and all appeals are heard — a process that can take years. Additionally, Vice President J.D. Vance said that most of the fraud his task force has uncovered would not be eligible under that program.

The Fraud Whistleblower Incentive Program appears to be a “pilot program,” according to an FAQ page, although announcements of the program have not described it in those terms. The DOJ said it will pay whistleblowers between $10,000 and $30,000 “for information leading to criminal charges relating to certain subject areas.” According to a White House official, WHIP will have the ability to dispense $25 million in payments.

Awards are limited to information pertaining to “federal health care offenses and related crimes involving health care benefit programs or fraud against patients or others in the health care industry,” or “fraud on programs or benefits” administered by seven cabinet-level departments (Agriculture, Labor, Health and Human Services, Housing and Urban Development, Education, Veterans Affairs, or War) and the Small Business Administration.

Other eligibility criteria include voluntary participation, full cooperation, truthful and complete information, and no participation in the revealed crimes.

President Trump made his own announcement of the program before cameras in the Oval Office. “Today I’m thrilled to announce the Fraud Whistleblower Incentive Program,” he beamed. “Mark those words. Independent journalists and everybody and all Americans will now be able to go to the fraud.gov and report cases of corruption and theft of taxpayer dollars in their communities.”

“If you turn somebody in and … you find a billion dollars, we are giving a commission to that person of 1%,” Trump described. “It’s a lot of money. And, if it’s $10 billion, $200 billion, $400 billion, we’re giving a 1% commission to that person.” Trump continued describing the 1% commission for nearly two minutes.

However, Trump’s description of the program does not align with the information published by the Justice Department, which announced rewards between $10,000 and $30,000, with no mention of a percentage cut. The maximum reward would be 1% of $3 million, a fraction of the amounts Trump used as examples.

President Trump also claimed to have a personal role in executing the program. If there was disagreement about who should receive the reward, he insisted, “I will be the arbitrator of all of these decisions. In other words, I’ll determine whether or not the person is deserving … and I will be very generous, believe me.”

“You’ll get your money immediately, but I’ll make the determination,” Trump repeated. “If two people are fighting over it, maybe they’ll split it or maybe whatever, but I’ll make that determination.”

Trump’s comments left the impression that he could use this money to dispense to allies as he chose. However, the WHIP is a pilot program of the Justice Department, not the White House, which means there are numerous layers of bureaucracy between the program and the Oval Office.

Another issue lacking in clarity is when whistleblowers would receive a payment under WHIP. Trump said they would receive the money “immediately,” without giving a reference point — immediately after what? The DOJ described the reward coming “at a much earlier stage of prosecution,” and said the reward would be “for information leading to criminal charges.”

These vague statements could imply that whistleblowers would be eligible for reward as soon as federal lawyers file charges. But this interpretation is not the only one consistent with the statements, and it would seem to undermine the legal system’s presumption of innocence for the accused.

In at least one instance, however, the matter of timing is more-or-less moot. At the same sitting in the Oval Office, Trump presented a check to citizen journalist Nick Shirley. His video reporting on YouTube broke open the long-running Somali fraud scandal in Minnesota.

In particular, Shirley’s videos highlighted Fahima Egeh Mahamud, former CEO of the Future Leaders Early Learning Center, who pled guilty in July to fraud charges. Since Mahamud already pled guilty to the charges, no doubt remains about the commission of a crime.

Prosecutors say Mahamud stole $4.6 million in child care assistance claims and $850,000 in federal child nutrition assistance. A 1% commission on that amount of fraud would earn Shirley a reward of $54,500. Trump presented him with a check for $10,000, the minimum advertised by the DOJ.