Fraud By The Numbers

Fraud By The Numbers Series

  • Life Comes at You Fast: The Role of Whistleblowers in An Era of Constant Change

    We hope you have enjoyed this year’s installment of Fraud by the Numbers! I started off the month discussing the developments in enforcement in the year past. Boy, does 2025 feel like a long time ago, particularly for whistleblowers and fraud enforcement where it seems like there is something new to digest every day (even…

  • The Lure of U.S. Whistleblower Rewards Pushes HMRC to Launch its own Strengthened Reward Program

    Do not pass Go. Do not collect £200. Proceed directly to Washington. Until recently, that, in Monopoly terms, is what the UK’s would-be fraud whistleblowers have been doing.

  • State FCA Recoveries

    Despite the success of the Federal law and the state False Claims Acts, these twenty-one states do not have an equivalent law:  Alaska, Alabama, Arizona, Arkansas Idaho, Kansas, Kentucky, Maine, Mississippi, Missouri, Nebraska, North Dakota, Ohio, Oregan, Pennsylvania, South Carolina, South Dakota, Utah, West Virginia, and Wisconsin.1  Not having such a law may be costing…

  • Insider Trading Comes to the Prediction Markets

    On February 25, 2026, the CFTC’s Division of Enforcement issued a “Prediction Markets Advisory” with a blunt message: the belief that insider trading law stops at the edge of an event contract is a myth, and the CFTC has the authority to police fraud and manipulation on all commodities markets.1 Enforcement actions followed.  The first…

  • The $2.29 Billion Safety Net: What the FY2025 DOJ Statistics Say About Declined Cases

    On September 1, 2026, the Eleventh Circuit vacated and remanded the district court ruling in United States ex rel. Zafirov v. Florida Medical Associates, finding the qui tam provisions Constitutional under the Appointments Clause. This decision was significant in ensuring private relators’ ability to litigate and bring cases when the government declines intervention. The significance…

  • The Squeeze on Relator Shares in a Record Recovery Year

    2025 was a record year for FCA recoveries. For relator awards, not so much. Under the federal False Claims Act (FCA), a whistleblower (“relator”) who helps to successfully prosecute fraud against the government is entitled to an award between 15 to 30% of the total proceeds recovered by the government.1  For cases in which the government intervenes in…

  • Paycheck Protection Program (PPP) Fraud Continues to Add Up 

    The Paycheck Protection Program (PPP) was designed to deliver emergency financial relief to businesses during the COVID-19 pandemic. But the program’s unprecedented scale also created unprecedented opportunities for fraud. The Small Business Administration (SBA) ultimately guaranteed roughly $800 billion across more than 11 million PPP loans, making it one of the largest federal emergency lending…

  • DOJ’s Criminal Corporate Whistleblower Program: A New Tool in the Fight Against Fraud

    In August 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (“Program”) to uncover and prosecute corporate crime, fill the gaps of then-current whistleblower programs, and to incentivize those with information about corporate criminal wrongdoing to report original information about criminal conduct that might otherwise go undetected or be difficult to prove.   The Program…

  • The $3 Trillion Blind Spot

    Here is a number: roughly $3 trillion. That is one widely used estimate of the private credit market, depending on how the market is defined.1 Private credit is a broad label for privately negotiated lending outside traditional public markets.2 It has become a major source of financing; and it is one that is unusually hard to see into. Private loans rarely trade,…

  • The Wide World of Customs Fraud

    The Department of Justice (DOJ) recently trumpeted the success of the Trade Fraud Task Force, which racked up $1 billion in recoveries, penalties, forfeitures, and charged losses before reaching its first birthday. A large part of the Task Force’s remit is customs fraud, which involves underpaying duties owed to the United States for imports. Customs and Border Patrol, the…