Top 10 Whistleblower Awards for 2025 - False Claims Act Whistleblowers Dominate the List

By the Constantine Cannon Whistleblower Team

As we reported in our post on the Department of Justice (DOJ) annual False Claims Act roundup, 2025 was a record year for False Claims Act recoveries, with DOJ bringing in $6.9 billion under the statute last year.  The majority of that amount — more than $5.3 billion — came from actions originated by whistleblowers under the qui tam provisions of the statute.

What Type of Whistleblowers Made the 2025 Top 10 Whistleblower Awards List?

That may explain in some part why all but one in our listing of the Top 10 whistleblower awards for 2025 went to False Claims Act whistleblowers.  But the far bigger reason for this outcome is the significant drop off in awards under the SEC Whistleblower Program.

As we noted in our post last week on the SEC Annual Whistleblower Report, the $60 million in awards the SEC doled out last year fell far short of the big SEC award numbers in past years — $255 million in 2024, $600 million in 2023, $229 million in 2022, $175 million in 2020, and $168 million in 2018.

Did Any SEC or CFTC Whistleblowers Make the Top 10 List?

These blockbuster numbers led to the SEC program dominating the Top 10 listings over the last several years — 2024 (4 of the top 5), 2023 (5 of the top 10, including the top 2), 2022 (8 of the top 10), 2021 (4 of the top 5), and 2020 (6 of the top 10, including the top spot).  Not this year however, where not a single SEC award made the list, with the largest SEC award this past year coming in at a relatively meager $6 million (compared to the bounty of 8 and 9-figure awards that pervaded the program in previous years).

The CFTC Whistleblower Program was even more miserly this year with only two awards, totaling $2.5 million.  And there were no awards at all under NHTSA’s Auto Safety Whistleblower Program, which has only made a single award to date, and under both FinCEN’s Anti-Money Laundering and Sanctions Whistleblower Program and DOJ’s Corporate Whistleblower Awards Pilot Program, which have yet to make any awards.

The top whistleblower award this year was under the IRS Whistleblower Program, which has shown some serious signs of life, with its recent launch of a multi-year operating plan aimed at expanding the reach, visibility, and impact of the program.  This was followed by the agency’s heavy promotion of National Whistleblower Day.  No doubt, we can expect more IRS blockbuster whistleblower awards to come.

But the False Claims Act still reigns supreme when it comes to whistleblower awards.  Not only did it grab the other 9 spots on our Top 10 listing.  But the total whistleblower payout for the year under the statute was a whopping $330 million.  This brings the total tally of False Claims Act whistleblower awards to roughly $10 billion since 1986, when the statute was amended to significantly increase the incentives and protections of whistleblowers.[1]

With all that said, our Top 10 listing is immediately below.  Please note it is based on imperfect information and in many cases our best assessment of the scope of the likely award from the size of the Government’s recovery.

• • No. 1 – Credit Suisse IRS Whistleblowers ($510M DOJ recovery).  On May 5, DOJ announced that Credit Suisse Services AG pleaded guilty and agreed to pay over $510 million to resolve allegations that it conspired to help wealthy Americans evade taxes through secret offshore accounts from 2010 through 2021.  The whistleblowers who revealed the bank’s misconduct to the Government were all former Credit Suisse employees.

• • No. 2 – Apex Medical FCA Whistleblowers ($310M DOJ recovery).  On December 12, DOJ announced that wound graft company Apex Medical and its owners would pay $310 million for violating the False Claims Act and Anti-Kickback statute by billing the Government for medically unnecessary wound grafts resulting from illegal kickbacks.  DOJ did not identify the whistleblowers or the award they would receive from the proceeds of the Government’s recovery.

• • No. 3 – Walgreens FCA Whistleblowers (> $51M WB award).  On April 21, DOJ — together with DEA and HHS — announced that Walgreens would pay at least $300 million to settle DOJ charges of violating the False Claims Act and Controlled Substances Act through its filling of improper opioid prescriptions.  According to the Government, Walgreens pharmacies filled millions of unlawful prescriptions for opioids despite “clear red flags” that the prescriptions lacked a legitimate medical purpose, or were issued outside the usual course of professional practice.  The allegations originated in a whistleblower lawsuit filed by former Walgreens employees, who collectively received an award of 17.25% of the Government’s recovery.

• • No. 4 –  Gilead FCA Whistleblower ($202M DOJ recovery).  On April 29, DOJ announced that Gilead Sciences agreed to pay $202 million to settle allegations of violating the False Claims Act and Anti-Kickback Statute by paying physicians to speak at or attend sham medical conferences to induce them to prescribe various Gilead HIV drugs.  The allegations originated in a whistleblower lawsuit but DOJ did not identify the whistleblowers involved or the award they would receive.

• • No. 5 – Horizon NJ FCA Whistleblowers ($12M WB award).  On November 14, New Jersey Attorney General Matthew Platkin announced that Horizon Blue Cross Blue Shield of New Jersey would pay $100 million to settle allegations of violating the New Jersey False Claims Act by overcharging the State on its contract to administer the State’s employee benefit programs.  The State’s action originated from a lawsuit filed by six whistleblowers under the qui tam provisions of the New Jersey False Claims Act.  As part of the settlement, the State agreed to provide five of the whistleblowers a whistleblower award of $12 million from the proceeds of the settlement.

• • No. 6 – Empire Pain Center FCA Whistleblower ($63.8M DOJ recovery).  On April 21, DOJ announced that two operators of New Jersey’s Empire Pain Center Holdings would pay $63.8 million for violating the False Claims Act and Anti-Kickback Statute by billing Medicare for medically unnecessary body braces and other durable medical equipment and exchanging kickbacks with telemedicine companies, physicians, and DME suppliers to further the scheme.  The matter was originated by Robert Jackson Tyler Jr., under the whistleblower provisions of the False Claims Act but DOJ did not disclose the amount of the award.

• • No. 7 – Seoul Medical FCA Whistleblower ($58.7M DOJ recovery). On March 26, DOJ announced that California-based Seoul Medical Group and its subsidiary Advanced Medical Management would pay $58.7 million to settle allegations they violated the False Claims Act by inflating the risk scores for their Medicare Advantage patients to inflate their Medicare reimbursement.  The allegations originated in a whistleblower lawsuit but DOJ did not identify the whistleblower or the amount of the whistleblower award.

• • No. 8 – Ceratizit FCA Whistleblower ($9.75M WB award). On December 18, DOJ announced that North Carolina-based Ceratizit USA would pay $54.4 million to settle allegations it violated the False Claims Act by failing to pay duties it owed Customs and Border Protection on the products it imported from China.  The allegations originated in a whistleblower lawsuit filed by Mark Stover under the qui tam provisions of the False Claims Act, who will receive a whistleblower award of roughly $9,750,000 from the proceeds of the Government’s recovery.

• • No. 9 – Biohaven FCA Whistleblower ($8.4M WB award).  On January 24, DOJ announced Pfizer subsidiary Biohaven Pharmaceutical Holding Company would pay roughly $60 million to settle allegations of violating the False Claims Act and Anti-Kickback Statute by paying kickbacks to healthcare professionals through paid speaker programs.  Pfizer terminated the programs after it acquired Biohaven.  The allegations originated in a whistleblower lawsuit filed by former Biohaven sales representative Patrica Frattasio, who received a whistleblower award of $8.4 million from the proceeds of the Government’s recovery.

• • No. 10 – Semler/Bard FCA Whistleblowers ($6.5M WB award).  On September 26, DOJ announced Semler Scientific and its former distributor Bard Peripheral Vascular would pay $37 million to settle charges they violated the False Claims Act through their sale of their FloChec and QuantaFlo diagnostic tests.  According to the Government, Semler/Bard told healthcare providers that Medicare reimbursed for these tests even though Semler knew it did not and even after some providers raised coverage concerns.  The allegations originated in a whistleblower lawsuit filed by Robert Kane and Franklin West, who will receive a total whistleblower award of roughly $6.5 million from the settlement.

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When Can We Expect the First FinCEN and DOJ Pilot Program Whistleblower Awards?

Constantine Cannon whistleblower partner Gordon Schnell was not surprised by this year’s Top 10 listing given the drop-off in SEC and CFTC awards this year, the lack of any activity in the NHTSA program for quite some time, and the relative infancy of the FinCEN and DOJ Pilot programs.  He expects a very different whistleblower award mix in the coming years.

According to Schnell, “FinCEN is poised to issue some hefty awards as the program matures and the agency has had time to investigate and develop the numerous tips that have come into the program over the past few years.”  Schnell points to FinCEN’s launch last month of a dedicated whistleblower webpage as a “very strong indication the agency is only getting more serious about and committed to the program.”

Schnell believes the same is true with DOJ’s Pilot Whistleblower Awards Program, especially after the Trump Administration expanded the program last summer to cover a wider swath of fraud and misconduct.  “Once these programs issue their first award,” Schnell says, “they will receive a lot of attention and serve as a catalyst for additional whistleblowers to come forward, which in turn will lead to more whistleblower awards down the road.”

That is what happened with the SEC program after it issued and heavily promoted its first awards several years ago.  Schnell sees that beginning to happen with DOJ’s recently launched Antitrust Whistleblower Program, which issued its first award last month.  And Schnell sees the same pattern repeating itself with FinCEN and the DOJ Pilot program in the very near future.  “So stay tuned,” Schnell remarks.  “Big awards from these new whistleblower programs are just around the corner.”

Constantine Cannon Has Substantial Experience Representing Whistleblowers Under the False Claims Act and Other Whistleblower Rewards Programs

Constantine Cannon has substantial experience representing whistleblowers under the False Claims Act and the many other whistleblower rewards programs, with several record-breaking successes.  In total, our representations have led to more than $1 billion in Government and whistleblower recoveries. This is in addition to the roughly $10 billion we have recovered for the firm’s other clients, including three of the top five antitrust settlements in U.S. history.

If you would like to learn more about our work, the various whistleblower rewards programs, or what it means to be a whistleblower more broadly, please do not hesitate to contact us.  We will connect you with an experienced member of our whistleblower team for a free and confidential consultation.  Maybe you will be the whistleblower who originates one of the next big Top 10 recoveries!

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Sources:

[1]  See https://www.justice.gov/opa/media/1424121/dl.

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