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New AML Whistleblower Law Jan 4, 2023

On December 23, 2022, Congress agreed to include the AML Whistleblower Improvement Act as part of the Omnibus Budget signed into law by President Biden. A new era of robust transnational whistleblower protections commenced. Whistleblowers from around the world now have a pathway to combat corruption effectively. For the first…

SEC Exceeds $1 Billion in Whistleblower Awards Sep 16, 2021

The Securities and Exchange Commission (“SEC”) announced that its whistleblower program has now paid more than $1 billion in awards to 207 whistleblowers since its first award in 2012, and has paid over $500 million to 101 whistleblowers in fiscal year 2021 alone. The awards can range from 10% to…

SEC Slightly Increases Dollar Amount Thresholds for “Qualified Client” Jul 7, 2021

The Securities and Exchange Commission (“SEC”) has slightly adjusted the dollar amount thresholds for assets-under-management and net worth tests for a “qualified client”. Registered investment advisers have generally been prohibited from charging a client a performance fee unless the client is a qualified client, defined to include a client with…

Record Number of Health Fraud Cases Reported by DOJ Jun 29, 2021

The DOJ opened over 900 False Claims cases last year involving healthcare fraud and is focusing on misuse of electronic health records, contribution to the opioid epidemic, abuse of senior citizens, manipulation of Medicare’s managed care program, and improper claims of COVID-19 relief funds. The False Claims Act (FCA) is…

SEC Whistleblower Program awards $175 Million in 2020 Dec 2, 2020

The U.S. Securities and Exchange Commission’s (“SEC”) Whistleblower Program released its Fiscal Year (FY) 2020 Annual Report (the “Report”) to Congress on November 16, 2020. According to the Report, the SEC received over 6,900 whistleblower tips during FY 2020 (which ended September 30, 2020), which was a 31% increase from…

New SEC Rules and Deadlines Could Impact Thousands of Cases Nov 11, 2020

On November 5, 2020, rule changes to the SEC Whistleblower Program were published in the Federal Register. Although December 7, 2020 is the effective date of these rule changes, the new rules created several deadlines that apply retroactively, requiring SEC whistleblowers and their attorneys to be very attentive to and…

SEC Adopts Amendments That Ease Limits and Rules on Private Offering Exemptions Nov 10, 2020

The Securities and Exchange Commission (“SEC”) adopted amendments proposed in March 2020 in order to simplify, harmonize and modernize the private offering framework in an effort to promote capital formation while preserving investor protections. The amendments generally: establish more clearly the ability of issuers to move from one exemption to…

Record $114 Million Whistleblower Award Issued by SEC Oct 23, 2020

The Securities and Exchange Commission (“SEC”) announced a $114 million reward to a whistleblower, making it the highest award in the program’s history and eclipsing the next highest award made in June 2020 for $50 million. The $114 million award consists of an approximately $52 million award in connection with…

Recent Amendments to SEC Whistleblower Award Program Oct 5, 2020

The Securities and Exchange Commission (“SEC”) has adopted amendments to the whistleblower program rules that the SEC suggests are designed to provide greater clarity to whistleblowers and increase the program’s efficiency and transparency.   The SEC has awarded approximately $523 million to 97 individuals since the program began. In the past…

Novartis Whistleblower Awarded $109 Million Jul 31, 2020

Novartis whistleblower, Oswald Bilotta, has been awarded $109 million by DOJ after an agreement in which the Swiss pharmaceutical company agreed to pay $629 million to settle claims accusing it of misrepresenting sponsored events as educational,  consisting of lavish events and expensive alcohol, with the intent of attempting to incentivize…