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Precious Metals, Costly Fraud

Posted  02/4/22
stack of coins
Safeguard Metals LLC and its principal, Jeffrey Santulan a/k/a Jeffrey Hill were hit with multiple enforcement actions this week, alleging fraud in their sale of securities and commodities to investors they targeted to sell their existing securities and invest the proceeds into gold and silver coins.  The CFTC and 27 state security regulatory agencies jointly filed one action, and the SEC filed its own action.  Both...

Top Ten Financial and Healthcare Fraud Prison Sentences of 2021

Posted  01/28/22
handcuff and money
Individuals involved in financial and healthcare fraud schemes face not just civil liability, but also criminal penalties – including prison time. In 2021, the Department of Justice obtained substantial prison sentences in a myriad of cases involving healthcare and financial frauds, many of which involved convictions of the type of fraudulent schemes that whistleblowers report. Whistleblowers play an essential role...

Top Ten Federal Financial Fraud Recoveries of 2021

Posted  01/21/22
Money with Gavel and Handcuffs
While 2021 may have felt like more of the same as the pandemic dragged on, it marked some new trends in federal financial fraud recoveries. As we predicted last year, the Anti-Money Laundering Act of 2020 has heralded some large recoveries against banks. The Act also established an Anti-Money Laundering Whistleblower Program, so that whistleblowers who report financial institutions engaging in money laundering –...

Top FCPA Recoveries of 2021

Posted  01/14/22
desk globe
We wish we could provide a list of the Top Ten FCPA recoveries of 2021.  But, in 2021, there were just four FCPA settlements announced by government enforcement agencies.  Following back-to-back years with billions of dollars in recoveries under the Foreign Corrupt Practices Act in 2020 and 2019 momentum has, unfortunately, stalled. The FCPA prohibits the payment of bribes to foreign officials made with the...

Top Ten SEC and CFTC Recoveries of 2021

Posted  01/7/22
Top Ten Sign with Letters
As we recently detailed, 2021 proved to be a blockbuster year for whistleblowers under the CFTC and SEC Whistleblower ProgramsSeven of the ten largest whistleblower awards of 2021 were made to SEC and CFTC whistleblowers, including a massive $200 million CFTC award that was roughly twice as large as all prior CFTC awards combined.  In total, the SEC paid more awards—both in total dollars and individual...

Top Ten Whistleblower Awards of 2021

Posted  01/6/22
Red Whistle with People
2021 was another banner year for whistleblowers, who once again collectively recovered billions of dollars for the government and hundreds of millions of dollars in whistleblower rewards under the various government whistleblower programs.  This includes awards under the qui tam provisions of the federal False Claims Act and various state False Claims Act programs.  It includes awards under the Dodd-Frank SEC...

SEC Whistleblower Program Reports Stunning 2021 Results

Posted  11/17/21
close up of capitol dome with United States flag
If you have been watching the SEC Whistleblower Program over the last year, you already know that this has been a big year, with the program passing one billion in total whistleblower awards as enforcement matters based on information from whistleblowers have resulted in orders for nearly $5 billion in monetary sanctions.  This week, the SEC released its 2021 Annual Report on the SEC Whistleblower Program, and, even...

SEC Names New Whistleblower Chief

Posted  11/12/21
Securities Exchange Commission Logo on Building
On November 5, 2021, the SEC announced that Nicole Creola Kelly would take over as Chief of the SEC’s Office of the Whistleblower.  The Office of the Whistleblower oversees the agency’s hugely successful Whistleblower Program, which has awarded about $1.1 billion to 226 individuals over the last decade.  Over the same period, those whistleblowers have helped the SEC obtain roughly $5 billion in financial...

Securities violation allegations for Trump SPAC again raises concerns on SPAC IPO model

Posted  11/3/21
Wall Street Sign in New York
Last year was the year of SPAC mergers.  Inevitably, perhaps, this year is shaping up to be the year of SEC investigations.  Just last week, we published a post about an SEC enforcement action against the Akazoo SPAC transaction after the target company was caught falsifying customer data.  Moments later, a huge new SPAC fraud story broke:  Donald Trump’s new media company’s recently announced SPAC merger may...

Akazoo Settlement with SEC Offers Lessons on Risks and Enforcement in SPAC Transactions

Posted  10/28/21
The Securities and Exchange Commission this week secured court approval of a $38.8 million settlement with music streaming business Akazoo S.A. – or, as the SEC pointedly describes the company, “a purported music streaming business,” because the company that publicly claimed to have millions of paying customers, in fact, had none.  The settlement marks the second public announcement of an SEC recovery in an...
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