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Top Ten Lists

Every January, Whistleblower Insider looks back at the significant government enforcement actions of the past year. Our Top Ten lists highlight the biggest recoveries and significant enforcement efforts by different government actors in cases involving fraud against federal and state governments, financial fraud, tax fraud, and environmental fraud.

Top Ten State Fraud Recoveries of 2021

Posted  01/21/22
government building stairs
State enforcement of anti-fraud laws is an important deterrent and tool to create accountability.  In cases of healthcare fraud and financial fraud, including government contract fraud, unlawful kickbacks, and tax evasion, state governments act as critical enforcement authorities, including through state False Claims Acts. Whistleblowers with information about fraud that violates state laws, or involves state...

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 Ten Tax Recoveries for 2021

Posted  01/19/22
Currency Zoomed In
Our top tax recoveries for 2021 total over $7 billion, an impressive number that is due largely to just one of our top ten tax recoveries. Tax evaders were creative last year, utilizing offshore banking, good old tax fraud, and forum shopping for an accounting opinion that fits—all with the intention of cheating the IRS and, in return, the taxpaying public. IRS Criminal Investigation flexed its muscles and went...

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 Healthcare Fraud Recoveries of 2021

Posted  01/11/22
doctor holding stethoscope
Consistent with the trend in prior years, the bulk of the Justice Department’s fraud and false claims recoveries in 2021 stemmed from healthcare fraud matters. Most of the funds recovered arose from cases originated by whistleblowers under the qui tam provisions of the False Claims Act. The majority of the recoveries on this list involve allegations of violations of the Anti-Kickback Statute, a federal law that...

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 Non-Healthcare False Claims Act Recoveries of 2021

Posted  01/7/22
Abe Lincoln
Our roundup of 2021’s Top Ten Non-Healthcare False Claims Act (FCA) recoveries illustrates the statute’s continuing capacity to fight both conventional and emergent frauds straddling a variety of industries. In 2021 alone, the United States recovered hundreds of millions in taxpayer funds obtained through false claims tainted by textbook contracting fraud schemes (overbilling on government contracts, selling the...

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...

Channeling the Whistleblower In Bob Dylan: His Top Ten Lyrics On Standing Up for Truth

Posted  05/28/21
Bob Dylan Mural
Hard to believe this music and literary icon of the 1960's, and every generation since, turned 80 this week (May 24).  With hundreds of songs, thousands of concerts, tens of millions of album sales, and an artistic career spanning more than half a century and counting, Bob Dylan's influence and contributions to the greater good have been boundless.  His litany of accolades offers just a taste of his grand...

Top Ten Environmental Fraud Settlements for 2020

Posted  03/12/21
Clear Light Buld Placed Over a Plant
In many ways, the COVID-19 pandemic uprooted our routines and put life on pause in 2020. But environmental fraud continued unabated, and so did enforcement actions against the perpetrators. We saw two major enforcement actions relating to devices designed to evade emissions requirements, several enforcement actions relating to water contamination and the knowing sale of products containing harmful pollutants, and...
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