Whistleblowers Can Carry the Torch for Fraud Fighting!
During the past month, Fraud by the Numbers has explored the pervasive nature of fraud on the government and financial markets across sectors, and the efforts to fight that fraud. While the scope of the problem is enormous, recoveries are still small compared with the hundreds of billions of dollars lost to fraud each year. But the enforcement trend is moving in the right direction. The Department of Justice (DOJ) recovered slightly more in 2024 than the year before in False Claims Act (FCA) cases. The Commodity Futures Trading Commission (CFTC) received a record number of tips and paid out approximately $42 million to whistleblowers, up from just $16 million in 2023. The Securities and Exchange Commission (SEC) received a record-breaking 24,980 tips in fiscal year 2024. The IRS collected $474.4 million attributable to whistleblowers, up from $338 million in 2023.
To complement those numbers, the government has launched two new whistleblower programs: DOJ Criminal Division’s Corporate Whistleblower Awards Program and DOJ Antitrust Division’s Whistleblower Rewards Program. All signs point to the government’s commitment to rooting out fraud and pursuing those responsible for bilking the taxpayers, investors, and consumers.
While the desire and structures to fight fraud may be alive and well in 2025, the current administration has also prioritized reducing the federal workforce. According to the U.S. Office of Personnel Management, there were 2,289,472 federal civilian employees as of March 31, 2025, down from 2,313,216 on September 30, 2024. “This reduction of more than 23,000 positions reflects the administrationʼs early efforts to streamline government and eliminate unnecessary bureaucracy.” Other efforts include a hiring freeze announced in January 2025. The number of federal civilian employees, including attorneys, investigators, and other personnel across agencies, is expected to drop by hundreds of thousands more “when workers depart the federal government as part of the Deferred Resignation Program.” A slowdown in enforcement is inevitable, and is already being felt, particularly at the SEC and CFTC.
However, it doesn’t have to be so! We can have more robust fraud enforcement even as the administration implements its downsizing efforts. Whistleblowers and their counsel bring enormous amounts of information, grit, and resources to the table and can provide essential assistance to government enforcement efforts. When the public-private partnership works at its best, whistleblowers and their counsel help ease the government’s burden by adding private resources to the government’s enforcement efforts. And, when the government allows whistleblowers to pursue cases on its behalf, we have seen some of the largest settlements in history.
Further, you may have noticed several posts on state FCAs during our Fraud by the Numbers month. Thirty-four states have FCAs. Some only apply to Medicaid but others have enacted specific laws for fighting cryptocurrency fraud, tax fraud, and other kinds of procurement fraud. States need whistleblowers just as much as the federal government to protect scarce state dollars lost to fraud. The Attorney Generals of those states stand ready to fight fraud when they get these cases.
While federal government resources are scarce (and they always have been), whistleblowers can be the lifeline for continued robust enforcement.
Thank you for joining us for our fifth year of Fraud by the Numbers! And, thank you again to everyone who made this month possible:
– The Anti-Fraud Coalition staff in addition to myself: Grace Swindler (Director of Legal Education) and Devan Eaton (Public Interest Advocacy Fellow)
– The Anti-Fraud Coalition Members: Clay Wire (Ogborn Mihm), Kate Scanlan (Keller Grover), Rachel Rose (Rachel V. Rose – Attorney at Law), Nick Mendoza (Murphy Anderson), Max Voldman (Whistleblower Partners), Clark Bolton (Morgan & Morgan), Li Yu (Bernstein Litowitz Berger Grossman), Gina Poserina (Costello & Silverman), and Liz Soltan (Whistleblower Partners) for their contributions in writing and editing many of the posts in this project.
As we close the 2025 series, we leave you with some highlights to consider from this month’s posts:
2024 set a remarkable record for new qui tam lawsuits filed by whistleblowers: almost a thousand (979) qui tam cases were filed in 2024.
– The SEC paid out its fifth-largest award in the program’s history: $98 million shared between two whistleblowers
– Customs fraud is a priority for the Trump Administration, and the United States is the world’s largest importer, bringing in an estimated $2.49 trillion worth of goods and services in 2024, following $3.85 trillion in 2023.
– Even in states with FCAs that only apply to Medicaid, the recoveries can be large: In 2025, Texas touted a $42.7 million recovery in a matter brought under the TMFPA.
– COVID fraud remains alive and well: In June 2025, DOJ and HHS-OIG announced the largest healthcare fraud takedown in history with 324 defendants across 50 federal districts and amounting to $14.6 billion in fraud. A significant portion of those cases involved COVID-19 related fraud, including fraudulent billing for lab testing.
– The FBI reported $9.3 billion in cryptocurrency fraud losses in 2024, a 66% increase from 2023.
– In 2024, the federal government recovered about $93 million in Department of Defense (DOD) via FCA cases. That’s a mere 3.2% of the over $2.9 billion recovered through the FCA in 2024. Meanwhile, 57.4% of that $2.9 billion ($1.675 billion) was for healthcare cases.
– In the last decade, PE firms have invested over $1 trillion in the U.S. healthcare sector, with more than $200 billion in acquisitions in 2021 alone.
– FY 2024, the total value of IRS whistleblower awards increased 39% in 2024, reaching $123.5 million.
Federal and state governments spend an enormous amount of their resources on prescription drugs. $137 billion, or roughly 1/6th of the Medicare budget, which pays for everything from major surgeries to nursing homes to dialysis, goes to cover pharmaceuticals.
– As of April 2024, “New York ha[d] recovered about $588 million in tax cases, including whistleblower awards of about $112 million.”
– The U.S. Sentencing Commission reports that money laundering offenses increased by 45% between fiscal year 2020 and fiscal year 2024, with 1,095 cases involving money laundering offenses in 2024.
– Department of Veterans Affairs (VA) ranks as the civilian agency with the most committed contracts, weighing in at $66.9 billion.
– From July 2024 to July 2025, across both state and federal False Claims Act cases, 292 settlements were announced totaling over $4.9 billion.
See you next year!
This piece was written by Jackie DeMar, President and CEO of TAF Coalition.
