Whistleblower programs seek to incentivize people with knowledge of crimes to come forward, representing a fundamental shift from the government’s historical dependence on sources who emerged through happenstance or arrest. Winston & Strawn’s Matt Graves, who announced the District of Columbia’s September 2024 whistleblower program as then-US attorney, and Kennedy Mackey map the progression from the Antitrust Division’s first-on-the-bus corporate leniency policy through multiple Biden Administration programs to the 2024 pilot initiatives that expanded both geographic reach and criminal scope beyond previously covered statutes.
While law enforcement uses a variety of tools to identify and disrupt fraud and public corruption schemes, no tool is more important than identifying people with knowledge of such schemes and incentivizing them to report on them. For many years, law enforcement did not make any concerted effort to convince sources to come forward, largely depending instead on good Samaritans who reported improper conduct because it was the right thing to do or individuals who were arrested for a crime reporting other crimes of which they were aware to try to gain more favorable treatment.
Good Samaritans and arrested individuals trying to decrease their own criminal exposure have been, and will continue to be, an important source of information. But relying on such sources is necessarily a reactive strategy: The government waits to see who comes forward and...
The federal government accused the medical providers of performing medically unnecessary procedures. PHOENIX — A physicians group in Phoenix has agreed to pay over $4 million to resolve allegations...