By the 91pornWhistleblower Team

The Department of Justice recently announced a $6 million settlement from a laboratory CEO, physicians, and marketers who allegedly used management services organizations (“MSOs”) as vehicles for illegal kickback payments.¹�� MSOs are business entities that provide administrative and other services to healthcare providers, but in this case they were allegedly used to disguise kickback payments as investment distributions. Former True Health Diagnostics CEO Christopher Grottenthaler agreed to pay $4.25 million for his role in the scheme, and two physicians and seven marketers also agreed to pay $1.82 million to resolve the case.

MSOs as a Cover for Kickbacks

According to the DOJ, marketers, including True Health employees, allegedly offered and paid physicians kickbacks disguised as MSO “investment” distributions to induce referrals. Grottenthaler allegedly facilitated True Health’s continued participation in the scheme even after receiving warnings that the marketers “are a powder keg waiting to explode on us” and that “people are gonna go to prison.”

The settlement also resolves allegations that Grottenthaler arranged for True Health to pay additional kickbacks disguised as consulting fees, processing and handling fees, and waivers of copayments and deductibles to induce laboratory testing referrals.

The DOJ Prioritizes False Claims Act Kickback Cases

The DOJ has prioritized enforcement of the Anti-Kickback Statute and Stark Law related to purported MSOs. Classic signs that an MSO is being used to facilitate kickbacks include paying investor returns with no meaningful risk or services provided, and parallel inducements such as “consulting” fees or copay waivers made alongside MSO distributions.

With this settlement, the DOJ has secured over $59 million in civil False Claims Act recoveries for kickbacks to healthcare providers disguised as MSO investment distributions.

Marlene Koury, partner at Constantine Cannon, noted that “MSO ‘investment’ arrangements that lack genuine business risk or correlate payments with referral volume are red flags for potential AKS violations. Creative structuring cannot disguise what are fundamentally illegal inducements.”

Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division stated “The Department of Justice will continue to pursue and prioritize healthcare fraud, including redressing illegal kickbacks. Kickbacks to doctors can undermine medical decision-making, subject patients to wasteful medical treatments, and squander taxpayer money.”

The DOJ Relies on Whistleblowers to Report MSO Kickback Schemes

This case originated from a qui tam lawsuit filed by STF LLC under the False Claims Act’s whistleblower provisions. The government intervened and expanded the case, adding several additional claims and defendants. The DOJ noted in its press release that the government’s pursuit of this case “illustrates the government’s emphasis on combating healthcare fraud,” further noting that “one of the most powerful tools in this effort is the False Claims Act.” The relators in this case will receive $148,750 as a reward.

91pornHas Substantial Experience Representing Whistleblowers

If you would like to learn more about our other��whistleblower successes,��kickback cases, the��False Claims Act, 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 the��91pornwhistleblower team��for a free and confidential consultation.

Speak Confidentially With Our Whistleblower Attorneys

Sources:

¹ See

Read DOJ’s MSO Kickbacks Crackdown Continues with $6M Settlement at constantinecannon.com

By the 91pornWhistleblower Team

DOJ Launches Cross-Agency Task Force with DHS

Last Friday (August 29), the Department of Justice (DOJ) launched what it describes as “a cross-agency Trade Fraud Task Force to bring robust enforcement against importers and other parties who seek to defraud the United States.”¹��More specifically, DOJ is partnering with the Department of Homeland Security (DHS) to “aggressively pursue” evading tariffs and other customs duties, and smuggling prohibited goods into the country. ��With this new Task Force, DOJ is tripling down on its crusade against customs fraud.

DOJ Continues to Ramp Up Customs Fraud Enforcement

First is DOJ’s recent expansion of the Corporate Whistleblower Awards Pilot Program.�� This is the program DOJ launched last summer to focus on criminal activity that generally falls outside the established whistleblower rewards programs such as the False Claims Act��and the��SEC ���Ի���FinCEN��whistleblower programs.����In May, DOJ announced it was broadening the program with customs and tariff fraud as one of DOJ’s key new areas of expanded focus.

Second is DOJ’s recent string of heavily promoted False Claims Act customs fraud settlements.�� Two weeks ago, Dallas-based countertop and cabinetry supplier Allied Stone agreed to pay $12.4 million to settle DOJ charges of evading customs duties by mischaracterizing the products it imported from China.�� Just a few weeks before that, DOJ extracted millions more in customs fraud settlements from MGI International and Grosfillex for similarly trying to evade customs duties on the products it imported from China.�� And in March, Evolution Flooring paid $8.1 million to settle similar DOJ charges of customs fraud.²

Third is DOJ’s new Task Force, which formally incorporates DHS into DOJ’s anti-fraud campaign, and in particular, the Customs and Border Protection and Homeland Security Investigations (HSI) units.�� As HSI Assistant Director for Global Trade Ivan Arvelo stressed: “Enforcing U.S. international trade laws is one of our agency’s top priorities, and this revitalized and expanded Trade Fraud Task Force is a significant step in the right direction.”

DOJ Calls on Customs Fraud Whistleblowers For Help

In announcing the new Task Force, the Government also put out the call to whistleblowers to join the fray by providing inside information under the Corporate Whistleblower Awards Pilot Program or through initiating a False Claims Act lawsuit under the qui tam provisions of the statute. ��These provisions allow private parties to bring lawsuits on behalf of the Government against those committing fraud against the Government.�� In return, successful whistleblowers can receive up to 30% of the Government’s recovery.

Given the complex nature of customs avoidance schemes and the efforts companies take to disguise them, company insiders with a direct window into the fraud may be the only way for the Government to find out about it. ��Unsurprisingly, the majority of customs fraud False Claims Act cases have been initiated by whistleblowers, including the recent Allied Stone, Grosfillex, and Evolution Flooring matters.

A Definite Uptick in Customs Fraud Whistleblowers Coming Forward

91pornwhistleblower partner Gordon Schnell was heartened by DOJ’s explicit shout out to whistleblowers and what DOJ hailed as their “vital contributions” in this area. ��According to Schnell, “This not only shows a clear recognition of the critical role whistleblowers play in reporting customs fraud, but that DOJ is counting on them to be a major part of this priority enforcement area.”

Schnell has noticed a definite uptick in the number of customs fraud intakes 91pornhas received over the last few months and encourages those with information on potential violations to come forward.�� The classic customs avoidance schemes to look out for, he advises, include: underreporting the value of the imports; mischaracterizing the nature or quantity of the goods; or misidentifying their country of origin.

91pornHas Substantial Experience Representing Customs Fraud Whistleblowers

Schnell says, “The Government has made it very clear that if you have information on potential customs violations, it wants to hear from you, and is willing to reward you for bringing information that leads to a successful enforcement action.”

91pornhas substantial experience representing customs fraud whistleblowers under the False Claims Act. ��In one of the firm’s more recent cases, we represented a whistleblower alleging an auto parts distributor misclassified brake pads imported from Asia to avoid millions of dollars of��customs duties.�� The company��settled��that matter for $8 million with the firm’s client receiving 18.5% of the Government’s recovery.

If you would like to learn more about our other��whistleblower successes,��customs fraud, the��False Claims Act, 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 the��91pornwhistleblower team��for a free and confidential consultation.

Speak Confidentially With Our Attorneys

Sources:

¹ See

² See

Read DOJ Triples Down on Crusade Against Customs Fraud — Calling All Whistleblowers at constantinecannon.com

By the 91pornWhistleblower Team

The Latest Customs Fraud False Claims Act Case

Last Tuesday (August 19), Dallas-based countertop and cabinetry supplier Allied Stone Inc. (and its president Jia Lim) agreed to pay $12.4 million to settle Department of Justice (DOJ) charges of violating the False Claims Act by evading customs duties on quartz surface products from China.¹ It is just the latest in a recent string of customs fraud settlements the Government has reached.

As we recently reported, DOJ settled two customs fraud cases just a few weeks ago.�� On July 23, MGI International subsidiaries Global Plastics and Marco Polo International agreed to pay $6.8 million to settle DOJ charges that they failed to pay customs duties on plastic resin imported from China.²�� And on July 24, Pennsylvania patio furniture company Grosfillex Inc. agreed to pay $4.9 million to settle DOJ charges of evading antidumping and countervailing duties on items made of extruded aluminum originating from China.³

DOJ Alleged Stone Schemed to Evade Customs Duties on Chinese Imports

With its latest customs fraud action, DOJ similarly alleged Allied Stone evaded the antidumping and countervailing duties it owed for its quartz surface imports from China.�� These duties are designed to protect American companies from foreign suppliers seeking to gain an unfair pricing advantage through foreign government subsidies or dumping products at below-cost rates.

According to the Government, Allied Stone mischaracterized its quartz surface products as marble or crystallized glass, which are subject to lesser duties, so it could significantly reduce what it owed CBP.�� DOJ and CBP have repeatedly stressed their commitment to go after this kind of customs misbehavior.

Customs Fraud is a False Claims Act Enforcement Priority

In announcing this most recent settlement, DOJ Civil Chief Brett Shumate specifically declared the agency’s “commitment to hold accountable those who evade or conspire to evade duties owed on imported goods, including antidumping and countervailing duties that level the playing field for American manufacturers.”�� He underscored that DOJ “will zealously pursue those who seek an unfair advantage in U.S. markets by evading or conspiring with others to evade duties owed.”

Executive Assistant Commissioner Susan Thomas of CBP’s Office of Trade echoed this sentiment, stating that “providing false information to CBP violates the law, and it is imperative that violators face consequences,” and that “CBP will always work alongside [DOJ] to ensure a level playing field for U.S. businesses.”

The Government was equally emphatic with its recent Global Plastics/Marco Polo and Grosfillex settlements that going after customs fraud is an enforcement priority, promoting the settlements as a warning for would-be violators going forward.�� 91pornwhistleblower partner Gordon Schnell points to this trio of customs fraud settlements as “a strong indication that DOJ and the Trump Administration have zeroed in on customs fraud as a key focus of their False Claims Act enforcement.”

Whistleblowers Have Initiated Most Customs Fraud False Claims Act Matters

According to Schnell, “Importers should take notice and ensure they are paying what they owe, as the Government is taking a zero-tolerance approach to customs fraud.”�� Schnell also points to the risk of whistleblowers coming forward to report on those companies that do not play by the rules.�� That is what prompted both the Allied Stone and Grosfillex matters.

Under the False Claims Act, whistleblowers may bring lawsuits on behalf of the Government against those committing fraud against the Government, and they can receive up to 30% of the Government’s recovery.�� Most False Claims Act cases are originated by whistleblowers, with whistleblowers collectively receiving close to $10 billion in awards over the last thirty years.

Whistleblowers have been especially prevalent in uncovering customs fraud because of how difficult it is to detect this type of wrongdoing without those on the inside with first-hand knowledge of the scheme or exposure to it. ��Unsurprisingly, both the Allied Stone and Grosfillex actions were originated by whistleblowers.

Former Allied Stone employee Melinda Hemphill originated that action and will receive more than $2 million from the proceeds of the settlement.�� Former Grosfillex employee Edward Wisner originated that action and will receive roughly $1 million from the settlement.�� And while a whistleblower did not formally originate the Global Plastics/Marco Polo action, a whistleblower was likely involved in reporting the conduct internally, leading to the company’s voluntary disclosure to DOJ and CBP.

91pornRepresents Customs Fraud Whistleblowers Under the False Claims Act

91pornhas substantial experience representing customs fraud whistleblowers under the False Claims Act.�� In one of our more recent cases, the firm represented a whistleblower alleging an auto parts distributor misclassified brake pads imported from Asia to avoid millions of dollars of��customs duties.�� The company��settled��that matter for $8 million with our client receiving 18.5% of the Government’s recovery.

91pornwhistleblower intake partner Alysia Solow notes the increase in customs fraud intakes over the past several months.�� “We have seen an increasing number of insiders reach out to us to report customs fraud schemes,” Solow says.�� She believes all the attention behind the Trump Tariffs is not only causing some companies to “cheat the system where they think they can,” but also is “putting a spotlight on the issue, prompting insiders to step forward when their company engages in this kind of fraud.”

If you would like to learn more about our other��whistleblower successes,��customs fraud, the��False Claims Act, 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 the��91pornwhistleblower team��for a free and confidential consultation.

Speak Confidentially With Our Whistleblower Attorneys

Read DOJ Continues Crusade Against Customs Fraud With $12.4M False Claims Act Settlement Against Allied Stone at constantinecannon.com

By the Constantine Cannon��Whistleblower Team

In the United States, financial rewards for whistleblowers are offered through several government programs designed to encourage individuals to report fraud, misconduct, or violations of the law.

What Is a Whistleblower Reward?

By initiating actions under the False Claims Act and other whistleblower reward laws and programs, whistleblowers may receive a percentage of the money the government recovers as a result of their information. If the information leads to a successful enforcement action, and the monetary sanctions exceed a certain threshold for certain programs, whistleblowers can receive a portion of the recovered amount.

These financial rewards serve as the basis of a public-private partnership between whistleblowers and the government agencies charged with investigating and prosecuting fraudsters. We’re diving into how financial rewards work for each whistleblower reward program below.

But first…

What Do You Need to Be a Whistleblower?

To qualify for many programs, the information concerning fraud or misconduct must be original, credible, and significantly contribute to the case. Various programs allow whistleblowers to report anonymously through an attorney and protect them from any retaliation.

91pornpartner Alysia Solow explained: “Contacting an experienced whistleblower attorney can help you understand and navigate the complex and ever-changing landscape of whistleblower laws in the United States.”

Attorneys like the whistleblower team at Constantine Cannon can help assess the merits of potential claims, evaluate the evidence you have, and identify and collect additional evidence, all while protecting your rights. Our dedicated team will work on your behalf with the government and help you make informed decisions as your claim proceeds.

Who Can Be a Whistleblower?

In the United States, almost anyone with credible information about wrongdoing can qualify as a whistleblower. This list can include:

• Current or former employees
• Members of the public if they have useful, non-public information
• Contractors or consultants
• Investors or shareholders
• Competitors

Rewards Under Government Whistleblower Programs:

Federal False Claims Act and Whistleblowers

• The federal��False Claims Act��(FCA) is the cornerstone of the U.S.��whistleblower reward system. The FCA provides that any person who knowingly submits or causes false claims to be submitted to the government is liable for three times the government’s damages plus penalties.
• Whistleblowers can bring claims under the FCA to report fraud and misconduct involving Medicare, Medicaid, and TRICARE healthcare fraud, including kickbacks, upcoding, risk adjustment fraud, and billing for services that are not provided or are not medically necessary. The FCA also applies to fraud in federal government contracts and programs, including overcharging or selling defective products to the government, education fraud, and underpaying customs and tariffs.
• The FCA allows private persons, known as��relators, to bring qui tam lawsuits��on the government’s behalf, and can potentially receive a reward of a portion of the government’s recovery between 15% and 30%.
• Learn more about the elements of a claim under the False Claims Act here.

State False Claims Act and Whistleblowers

• Whistleblowers with information that a state or local government has been defrauded may be able to bring a��qui tam suit under a state False Claims Act or a local False Claims Act. Many of these acts are modeled after the federal False Claims Act, with the same structure and elements, including awards provisions.�� Several states limit their FCA statutes to Medicaid fraud only and certain states have added tax fraud as an additional program feature.
• Successful suits have been brought against telecommunications companies, financial firms, charter schools, construction companies, Medicaid providers, and others.
• To learn more, review our additional info on state False Claims Acts with qui tam provisions and state False Claims Acts with no qui tam provisions.

The Securities and Exchange Commission (SEC) Whistleblower Reward Program

• The SEC Whistleblower Reward Program is for cases involving violations of securities laws, including market manipulation, false statements regarding a company’s financial condition, and insider trading.
• Under the��SEC Whistleblower Program, eligible whistleblowers are entitled to an award of up to 30% of the monetary sanctions collected in successful actions brought by the government.
• In determining the award percentage, the SEC considers various factors such as the significance of the whistleblower’s information and the extent of the whistleblower’s assistance.
• If the information provided by the whistleblower leads to a successful SEC action with monetary sanctions��exceeding $1 million, the whistleblower may then apply for a whistleblower reward.
• To learn more and to read examples of the types of fraudulent activity that can give rise to an SEC enforcement action, review our Financial & Investment Fraud page.

Anti-Money Laundering and Sanctions Whistleblower Program

• Whistleblowers can receive awards for reporting violations of the Bank Secrecy Act and sanctions laws, including banks failing to institute sufficient AML compliance programs or failing to file Suspicious Activity Reports, financing terrorist or criminal enterprises, and conducting business with sanctioned entities or countries.
• The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is charged with administering the Bank Secrecy Act. It has broad investigative powers and can bring enforcement actions seeking monetary penalties and other civil remedies through actions in federal court or administrative proceedings. FinCEN regularly works with other federal regulators, including the SEC and CFTC, as well as with the Department of Justice, which can bring criminal, civil, and forfeiture actions for violations of AML rules.
• Eligible whistleblowers can receive a reward of up to 30% of monetary sanctions over $1,000,000 that the government imposes based on the information the whistleblower provides.
• To learn more about the components of a sanctions violation claim under the AML Whistleblower Program, review our informational page.

DOJ Pilot Whistleblower Rewards Program

• In August 2024, the DOJ launched its Corporate Whistleblower Awards Pilot Program. It is designed to fill some of the gaps among the existing whistleblower rewards programs, including healthcare fraud against private insurers, bribery, and certain types of money laundering.
• Under the new pilot program, “A whistleblower who provides the Criminal Division with original and truthful information about corporate misconduct that results in a successful forfeiture may be eligible for an award.”
• The total amount of any award under the program for a particular matter, whether going to one or multiple whistleblowers, is as follows:
  • (i) up to 30% of the first $100 million in net proceeds forfeited (with a presumption of 30% for the first $10 million);
  • (ii) up to 5% of any net proceeds forfeited between $100 million and $500 million;
  • and (iii) no award on net proceeds forfeited over $500 million.
• Factors that may increase the size of the award include: the significance of the information the whistleblower provided, the level of assistance the whistleblower provided, and whether the whistleblower reported the information internally before going to the DOJ.
• Factors that may decrease the award include whether the whistleblower participated in or benefitted from the wrongdoing, the amount of any delay in reporting internally and to the DOJ, and whether the whistleblower served in a management role over those involved in the misconduct.

The DOJ Antitrust Whistleblower Rewards Program

• In July 2025, the DOJ Antitrust Division announced the Antitrust Whistleblower Rewards Program, which “will offer rewards for individuals who report antitrust crimes and related offenses that harm consumers, taxpayers, and free market competition across industries from healthcare to agriculture,” which may include horizontal per se��unlawful agreements such as price fixing, bid rigging, and market allocation schemes.
• DOJ is partnering with the Postal Service on this new initiative.
• We are especially thrilled about this new program since 91pornis an internationally renowned Antitrust and Whistleblower law firm.
• DOJ Antitrust Whistleblower Rewards Program largely follows the��SEC Whistleblower Program, which provides awards for those reporting violations of the securities laws.��That program has been very successful, with thousands of whistleblower tips annually, leading to billions of dollars of SEC recoveries.
• The amount of any award will be in DOJ’s sole discretion but presumptively between 15-30% of the criminal fine recovered.

The Commodity Futures Trading Commission (CFTC)��Whistleblower Program

• The Commodity Futures Trading Commission (CFTC) Whistleblower Program��encourages those with knowledge of��violations of the U.S. Commodity Exchange Act (CEA) to share this information with the CFTC. Violations may include manipulating the price of commodities or fraud or deceit in connection with the sale of commodities or futures contracts.
• Under the CFTC Whistleblower Program, eligible whistleblowers are entitled to an award of between��10% and 30% of the monetary sanctions collected in actions brought by the government.
• If the information provided by the whistleblower leads to a successful CFTC action resulting in an order of monetary sanctions��exceeding $1 million, the whistleblower may then apply for a��whistleblower reward.

The IRS Whistleblower Program

• The Internal Revenue Service’s Whistleblower Office incentivizes people to report tax evasion and other tax law violations.
• The IRS Whistleblower Program guarantees the whistleblower at least 15% and up to 30% of government tax collections that result from the whistleblower’s reporting to the IRS, to the extent those recoveries exceed $2 million.
• No reward is paid to the whistleblower until the IRS collects the taxes, penalties and interest owed, and all the statutory periods for a taxpayer to file a claim for a refund have expired.
• Previously successful claims have involved corporate tax fraud, vast tax avoidance schemes, and fraud by high-net-worth individuals. For example, in our Top 10 Whistleblower Awards for 2024��round-up, we discussed the $74 million awarded to three whistleblowers for reporting an offshore tax evasion scheme that led the agency to collect $263 million from an unidentified individual.

Motor Vehicle Safety Whistleblower Act

• In December 2015, Congress created the��Motor Vehicle Safety Whistleblower Act��to give current and former industry employees and contractors��a financial incentive to bring to light automobile safety-related problems.
• Under the Motor Vehicle Safety Whistleblower Act, a whistleblower can receive a reward of��up to 30% of any monetary sanctions��over $1,000,000 the government imposes based on the information the whistleblower provides. Existing law also offers vehicle-safety whistleblowers��protection against employer retaliation.
• A whistleblower can receive an award even if the safety violations that the whistleblower provided information about occurred before December 2015.
• Awards are based on the significance of a whistleblower’s information, the extent of the whistleblower’s assistance, and, in some cases, whether the whistleblower reported the information internally.
• Federal law protects a vehicle-safety whistleblower from employer retaliation.
• A whistleblower’s identity generally remains confidential.
• An eligible whistleblower is a current or former employee or contractor of a motor vehicle manufacturer, parts supplier (i.e., manufacturer of motor vehicle equipment), or dealership.
• A whistleblower does not have to be a U.S. citizen or resident, and violations he or she reports on don’t have to occur in the U.S. Whistleblowers can come from any country and can seek to expose actions occurring outside of the U.S. so long as some of the vehicles (or components) at issue are sold or otherwise distributed to the U.S. market.

Ocean Dumping Whistleblowers – The Act to Prevent Pollution from Ships (APPS)

• The Act to Prevent Pollution from Ships (APPS) whistleblower provision allows reporting of unlawful ocean dumping.
• Under the APPS, whistleblowers, even if they are not U.S. nationals, might receive up to one-half of collected fines or civil penalties.
• The APPS has generated over $33 million in whistleblower rewards to individuals and groups.
• APPS whistleblower awards recognize that numerous incidents of ocean pollution remain undetected unless witnesses come forward.��
• Conscientious mariners and others in the industry can help to fight against harm to ocean wildlife, fragile coral reefs, and ecosystems.

Examples of Other Whistleblower Programs for Specific Industries or Types of Wrongdoing:

• Acts in California and Illinois for whistleblowers reporting��fraud against private insurers.
  • California Insurance Fraud Prevention Act
    • The California Insurance Fraud Prevention Act (California Insurance Code sections 1871-1871.9) has a broad reach.
    • Examples of California Insurance Fraud Prevention Act violations include but are not limited to inflating the amount of a claimed loss, billing an insurance company for services that were not performed, paying kickbacks to doctors to get them to prescribe certain drugs, and presenting multiple claims for the same loss.
    • In a successful intervened action, the whistleblower will receive between 30% and 40% of the proceeds. A successful plaintiff in a non-intervened action will receive between 40% and 50% of the proceeds.
  • Illinois Insurance Claims Fraud Prevention Act
    • The Illinois Insurance Claims Fraud Prevention Act is similar to the California law which allows claims against private insurance companies.
    • Examples of the Illinois Insurance Claims Fraud Prevention Act violations include submitting a false claim to an insurer to obtain compensation, using deception to obtain health care benefits, and employing recruiters to procure clients or patients who will submit insurance claims.
    • If the state intervenes, a successful plaintiff will receive not less than 30% of the proceeds. If the state does not intervene, a successful plaintiff will receive not less than 40%.
  • FIRREA, the Financial Institutions Reform, Recovery, and Enforcement Act, for whistleblowers reporting frauds involving federally insured financial institutions.

• Wildlife protection laws��providing for whistleblower rewards.
• Colorado’s��Public Health Emergency Whistleblower (PHEW) Act��provides protections to essential workers and individuals who act to further workplace safety and health. In addition, the PHEW Act allows for whistleblowers to file��qui tam��actions��and receive a share of any government recovery.
• Some��states also provide awards for whistleblowers who disclose��securities��law violations to��state��authorities.�� State��securities��whistleblower laws have been enacted in��Indiana, Montana, ���Ի���Utah.

Our Firm Helps Whistleblowers

91pornhas extensive experience representing whistleblowers. Please��contact��us if you believe you have a case.��We will connect you with an experienced member of the 91pornwhistleblower��team��for a free and confidential consultation.

Speak Confidentially With Our Whistleblower Attorneys

Read Whistleblower Question of the Week: How Do Financial Rewards Work for Whistleblowers? at constantinecannon.com

In March 2020, Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and offered forgivable Paycheck Protection Program (PPP) loans to small businesses. This emergency relief was intended to help businesses with applicable expenses during the pandemic.

How Businesses Attempted to Defraud the Government During COVID-19

Many businesses used this time as an opportunity to defraud the government and failed to comply with the loan requirements. This included falsely certifying eligibility in terms of employee numbers, misrepresenting their income, and business size, among other requirements.

As per the two recent enforcement actions detailed below related to pandemic-era fraud, the government continues its commitment to enforcing laws that protect against COVID-19 fraud. Both were initiated by whistleblowers, underscoring the importance of reporting any knowledge of misconduct.

Convicted Felon and His Demolition Company to Pay $2.01M to Resolve Allegations Regarding False Applications for Pandemic Relief Loans

On August 9, the government announced that Charles Smith, Jr. and SMI Demolition, Inc., of Massachusetts agreed to pay $2.01 million to settle False Claims Act allegations that the company falsely certified its eligibility for two PPP loans and an Economic Injury Disaster Loan (EIDL) to the United States Small Business Administration (SBA) during the pandemic.[1]

Smith Falsely Certified His Company’s Eligibility

In April 2020, Smith owned 51% of SMI Demolition. On April 7, 2020, SMI Demolition applied for a PPP loan and certified that no owner had previously pleaded guilty to a felony involving fraud. However, Smith previously pleaded guilty to two counts of mail fraud in January 2018.[2]

Around the time the application was in progress, Smith and his associates prepared an agreement that claimed part of his ownership would be transferred to another person. The agreement was never finalized.[3]

SMI Demolition Received SBA Loans, An EIDL, and PPP Loans

SMI Demolition applied for and received two additional loans from SBA, an EIDL and a second PPP loan. The total amount of loans equaled $1,448,402. All but $150,000 was forgiven by the SBA.

Since the company was ineligible for PPP loans and the EIDL due to Smith’s felony convictions and ownership status, Smith and SMI Demolition caused false claims for payment to SBA, according to the government. Smith and SMI Demolition admitted to the aforementioned allegations.[4]

Case Initiated by a Whistleblower

As with many recent pandemic fraud cases, this complaint was originated by a whistleblower under the��qui tam��(or whistleblower provision) of the��False Claims Act, which allow private parties to file an action on behalf of the United States and receive a portion of any recovery.

Whistleblower Will Receive $200,000

The qui tam case is captioned United States ex rel. Forsyth v. SMI Demolition, Inc. and Charles Smith, Jr., No. 23-cv-10091-NMG (D. Mass.). The relator (or whistleblower) will receive approximately $200,000 from the resolution.[5]

More PPP Fraud – Three Chinese-Owned Companies, BWI Entities, Falsely Submitted for PPP Loans

In other PPP fraud news, on August 12, the government announced that three Chinese-owned companies agreed to pay $21,660,983 to resolve False Claims Act allegations relating to PPP loans for which they were not eligible.

BWI Entities were allegedly not eligible for the PPP loans since they were affiliated with other companies in China, Europe, and other countries around the globe. Collectively, BWI Entities employed more individuals than permitted by SBA’s size requirement. BWI Entities were also purportedly ineligible because they were owned by a government entity.[6]

Claims Originated by A Whistleblower

This settlement includes the resolution of claims brought under the qui tam provisions of the False Claims Act. The whistleblower lawsuit was filed by GNGH2 Inc., a corporate entity likely created to maintain the anonymity of the whistleblower. ��They will receive $2,166,098.30 as part of this settlement.[7]

The Role of Whistleblowers and COVID-19 Related Fraud

Whistleblowers are critical in exposing misconduct and sharing information concerning various types of fraud. This fraud can include��COVID-19��era information related to falsely certifying eligibility when applying for PPP loans, unauthorized use of funds, payment of��kickbacks��to obtain government contracts related to COVID-19, and more.

91pornpartner Dan Vitelli commented: “The government is committed to safeguarding emergency relief funds and holding accountable those who sought to exploit pandemic relief for personal gain. The government continues to bring enforcement actions against COVID-19 and pandemic-relief fraud, and it counts on whistleblowers to bring forward information they have concerning misconduct.”

Our Firm Helps COVID-19 Fraud Whistleblowers

Our firm handles cases related to COVID-19 fraud. If you have a potential case, please��contact us��to see how we can help.

Speak Confidentially With Our Whistleblower Attorneys

Sources:

[1] See

[2] Id at 1

[3] Id at 1

[4] Id at 1

[5] See

[6] See

[7] Id at 6

Read Two Recent Whistleblower-Initiated Cases Targeting Pandemic Scams Underscore the Government’s Commitment to Combat Fraud at constantinecannon.com

By the Constantine Cannon��Whistleblower Team

Forefront Dermatology S.C. (“Forefront”) and Henghold Surgery Center LLC (“Henghold Surgery Center”) will pay $847,394 to resolve allegations that they violated the False Claims Act by submitting falsely coded claims to Medicare for wound repairs.

The Dermatology Providers and the Procedures Allegedly Performed

Forefront owns and operates Henghold Dermatology, a dermatology practice in Florida. ��Dr. William B. Henghold owns an ambulatory surgery center, Henghold Surgery Center, which closed in 2023. Both facilities allegedly performed numerous wound repair procedures following skin cancer removal on patients who had undergone Mohs micrographic surgeries.¹

Submission of False Claims to Medicare

The government alleges that Henghold Dermatology and Surgery Centers caused the submission of false claims to Medicare by using inaccurate wound repair billing codes. As a result, Medicare paid more money than it normally would have for wound repairs.² This Medicare fraud scheme is known as upcoding.

According to the DOJ, Henghold Dermatology and Surgery Centers “falsely coded linear repairs as if they were flap repairs and falsely coded smaller flap repairs as if they were larger flap repairs.”³

“Schemes that cause Medicare to pay for costlier services than were actually performed waste taxpayer funding, threatening the integrity of this federal healthcare program,” said Deputy Inspector General for Investigations Christian J. Schrank of the U.S. Health and Human Services Office of Inspector General (HHS-OIG).⁴

This case bears some resemblance to a healthcare fraud settlement we blogged about earlier this year. In April, the government announced it filed a complaint under the��False Claims Act��against Vohra Wound Physicians Management LLC (Vohra), its entities, and its founder Dr. Ameet Vohra. Among other violations, the government alleged the company submitted false claims to��Medicare��for��upcoded ���Ի���medically unnecessary��wound care services.

Healthcare Fraud

Healthcare fraud can take many forms including taking��kickback��payments for services or patient referrals, billing for medically unnecessary services, upcoding, making false statements about covered services, and more. It is critical to recognize fraud and speak up against misconduct.

The Role Whistleblowers Play in Exposing Healthcare Fraud

This settlement includes the resolution of claims brought under the��qui tam��(or whistleblower) provisions of the False Claims Act by a former Forefront employee and whistleblower, Christopher Wolfe, M.D. Under the False Claims Act, private parties can file lawsuits on behalf of the government and receive up to 30% of any recovery. The whistleblower, Dr. Wolfe, will receive a $152,531 share of the settlement.

Our Firm Helps Healthcare Fraud Whistleblowers

“Holding healthcare providers accountable for fraud protects our tax dollars, ensures patients receive proper care, and upholds the integrity of federally funded programs like Medicare,” said 91pornattorney Dan Noel.

91pornhas over 15 years of experience representing healthcare fraud whistleblowers. Please��contact��us if you believe you have a case.��We will connect you with an experienced member of the 91pornwhistleblower��team��for a free and confidential consultation.

Speak Confidentially With Our Whistleblower Attorneys

Read Two Dermatology Providers To Pay $847K+ To Resolve Medicare Coding Fraud Claims For Wound Care Under the False Claims Act at constantinecannon.com

By the 91pornWhistleblower Team

Last Thursday (July 31), the Department of Justice (DOJ) announced the settlement of two False Claims Act cases involving cybersecurity fraud.�� The first, against California-based Illumina Inc., involved allegations the company sold federal agencies certain genomic sequencing systems with cybersecurity vulnerabilities.¹ ��The second, against California-based defense contractor Aero Turbine Inc. and its private equity partner Gallant Capital Partners, involved allegations Aero Turbine violated the cybersecurity requirements in a contract it had with the Air Force.²

DOJ Adds To the String of Recent Cybersecurity Fraud Settlements

Illumina agreed to pay $9.8 million to settle its False Claims Act matter.�� Aero Turbine and Gallant agreed to pay $1.75 million to settle their False Claims Act matter.�� The relatively low settlement number for Aero Turbine and Gallant is because of the “significant steps” they took in cooperating with the Government.�� These two matters are just the latest in a string of recent cybersecurity False Claims Act matters, reinforcing that going after cybersecurity fraud remains a top enforcement priority for the Trump Administration.

Government Flags Cybersecurity Vulnerabilities in Illumina’s Genomic Sequencing Systems

In the Illumina matter, the Government alleged the company sold Government agencies genomic sequencing systems with software containing numerous cybersecurity vulnerabilities without adequate protections to identify and address them. ��The Government provided the following examples:

• • A failure to incorporate product cybersecurity in its software design, development, installation, and on-market monitoring.
  • A failure to properly support and resource personnel, systems, and processes tasked with product security.
  • A failure to correct design flaws that introduced cybersecurity vulnerabilities.
  • Falsely representing the genomic sequencing system software adhered to cybersecurity standards, including standards of the International Organization for Standardization and National Institute of Standards and Technology (NIST).

Government Alleges Aero Turbine Failed to Implement NIST Cybersecurity Controls and Disclosed Defense Data Without Authorization

In the Aero Turbine matter, the Government alleged the company failed to implement certain NIST cybersecurity controls (under Special Publication 800-171 relating to confidential Government information) in its Air Force contract that “could lead to significant exploitation of the system or exfiltration of sensitive defense information.”�� The Government further alleged Aero Turbine and Gallant provided sensitive defense information to an Egyptian software company not authorized under the Air Force contract to receive it.

Cybersecurity Fraud Remains A Top DOJ Enforcement Priority

In announcing the settlements, a chorus of Government officials stressed the critical importance of maintaining proper cybersecurity controls and complying with all cybersecurity standards, and the Government’s commitment to go after federal contractors that do not play by these cybersecurity rules:

• • “This settlement underscores the importance of cybersecurity in handling genetic information and [DOJ’s] commitment to ensuring that federal contractors adhere to requirements to protect sensitive information from cyber threats.” [DOJ Civil Chief Brett Shumate]

• • “Safeguarding the validity of Department of Defense research and data is vital to supporting the warfighter.” [DoD Special Agent Christopher Silvestro]

• • “Protecting the integrity of the Department of Defense (DoD) procurement processes is a top priority for the DoD.” [DoD OIG Director Kelly Mayo]

• • “HHS-OIG and our law enforcement partners remain dedicated to ensuring that entities who do business with the Government uphold their cybersecurity obligations.”�� [HHS-OIG Special Agent Roberto Coviello]

• • “Ensuring companies adhere to robust cybersecurity safeguards is integral to maintaining the Air Force’s operational edge against adversaries.” [Air Force Special Agent Caroline Galinis]

As we noted in our May 2025 post (“Trump Administration Signals Strong Commitment to Stopping Cybersecurity Fraud”), the Government has brought several cybersecurity enforcement actions this year demonstrating its continued commitment to using the False Claims Act��to go after cybersecurity fraud.�� In that post, we reported on DOJ’s May 1 settlement with RTX subsidiary Raytheon Company and Nightwing Group where they agreed to pay $8.4 million to settle charges of violating key cybersecurity requirements in various Department of Defense contracts.

We also noted that in its 2024 False Claims Act��Roundup, DOJ highlighted cybersecurity failures as a primary focus of fraud enforcement.�� This has been a priority area since the agency’s 2021 launch of the����“to promote cybersecurity compliance by government contractors and grantees by holding them accountable when they knowingly violate applicable cybersecurity requirements.”

Whistleblowers Are Critical to Uncovering Cybersecurity Violations

91pornwhistleblower partner Gordon Schnell commented that with all these enforcement actions, “there seems little doubt the Trump Administration is committed to cracking down on contractors that fail in their cybersecurity obligations.”�� In an��article��he wrote last year for��Washington Technology, Schnell cautioned that “those doing business with the Government would be wise to get their data protection systems in order or they may find themselves next up on DOJ’s cybersecurity hit list.”

With these two most recent settlements, Schnell sees no slowing down in the Government’s focus on cybersecurity fraud.�� And as these cases make clear, the Government is willing to go after security failures even when they do not necessarily result in an actual breach.�� The risk of a security breach is enough for the Government to take action.

Like most False Claims Act cases, the Illumina action originated with a whistleblower lawsuit under the��qui tam��provisions of the statute, which allow private parties to bring lawsuits on behalf of the Government against those that defraud the Government.�� In return, successful whistleblowers can receive up to 30% of the Government’s recovery.

Illumina Whistleblower Erica Lenore to Receive $1.9 Million Award

The Illumina whistleblower was Erica Lenore, Illumina’s former Director for Platform Management.�� She will receive a whistleblower award of $1.9 million from the proceeds of the Government’s recovery.

Over the past 30 years, whistleblowers have received almost $10 billion in whistleblower awards under the False Claims Act.�� Whistleblowers play an especially critical role in uncovering cybersecurity fraud given the lack of visibility into the cybersecurity protocols most companies follow.�� While there is no indication a whistleblower originated the Aero Turbine action, given the voluntary nature of the company’s disclosure to the Government, there is a strong likelihood a whistleblower was involved internally in bringing the misconduct to the company’s attention.

91pornRepresents Cybersecurity Whistleblowers Under the False Claims Act

91pornhas substantial experience representing cybersecurity whistleblowers under the False Claims Act.�� Indeed, the firm represented the whistleblower in the��first successful cybersecurity case ever brought under the False Claims Act.�� That case resulted in Cisco Systems agreeing to pay $8.6 million to settle charges of selling the Government noncompliant video surveillance software vulnerable to unauthorized access and manipulation.�� Our client received a whistleblower award of 20% of the Government’s recovery.

If you would like more information about that case and our other work representing cybersecurity whistleblowers, or would like to learn more about��what it means to be a whistleblower��under the False Claims Act, please don’t hesitate to��contact��us.�� We will connect you with an experienced member of the 91pornWhistleblower��Team for a free and confidential consult.

Speak Confidentially With Our Whistleblower Attorneys

Read DOJ Continues False Claims Act Crusade Against Cybersecurity Violations: More Cybersecurity Whistleblowers Wanted at constantinecannon.com

By the��91pornWhistleblower Team

Delta Air Lines will pay $8,100,000 to settle allegations that it violated the False Claims Act by giving compensation to corporate officers and employees that surpassed monetary limits the company agreed to in 2020. This was part of the Department of the Treasury’s Payroll Support Program (PSP) that placed compensation caps for employees of participating companies.[1]

Pandemic Relief – The Department of the Treasury’s Payroll Support Program (PSP)

The PSP was created by Congress in March 2020 under the Coronavirus Aid, Relief and Economic Security Act (CARES). This provided payroll support to passenger and cargo air carriers and contractors to continue payments of employee wages, salaries, and benefits.[2]

Participating Air Carriers Were Required to Follow Conditions

The program was administered by the Department of Treasury (Treasury). Participating air carriers were required to enter into written agreements with the Treasury that detailed conditions to follow in exchange for the PSP funds. Requirements included limitations on the compensation that PSP participants could pay to employees that earned over $425,000 annually in 2019.[3]

Delta’s PSP Agreements in 2020 and 2021

In 2020 and 2021, Delta entered into PSP agreements with the Treasury and agreed to the compensation limits. Delta received roughly $11.9 billion in PSP funds, including at least $8.2 billion from grants that did not have to be repaid.[4]

How Delta Allegedly Violated the False Claims Act

By falsely certifying compliance with PSP requirements in quarterly reports submitted to the Treasury, and failing to notify of a breach when discovered by Delta, the company allegedly violated the False Claims Act.

The case settles charges that from March 2020 to April 2023, Delta allegedly awarded compensation to certain corporate officers and employees that far exceeded the limits set by the PSP agreements.

“The PSP was intended to provide critical assistance to the airline industry during the pandemic,” commented Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division. “The department is committed to holding accountable those who failed to abide by the terms and conditions governing their receipt and use of federal funds.”

Case Brought by a Whistleblower

This case was brought under the qui tam (or whistleblower provisions) of the False Claims Act by H. Remidez LLC. Under those provisions, private parties (called relators) can file lawsuits on behalf of the government and earn up to 30% of the recovery. In this case, the whistleblower will receive $850,500.

COVID-19 Fraud

COVID-19 fraud has taken many forms. Here are just some types of pandemic-related fraud:

• Fraud in Government Spending and Government Programs
• Medicare Fraud that Targets Regulatory Changes in Response to COVID-19
• Financial and Investment Fraud
• Other Fraud Schemes Arising from the COVID-19 Pandemic

Our Firm Helps COVID-19 Fraud Whistleblowers

According to 91pornpartner Marlene Koury, “Years later, COVID-19 related fraud is still being exposed. Whistleblowers are essential to bringing such fraud to light and aiding government enforcement efforts to hold bad actors accountable.”

If you blow the whistle on a company or individuals who committed fraud in applying for COVID-19 relief funds, spending those funds, or other fraud, you may be eligible for a reward under the��False Claims Act��or other��whistleblower reward programs. If you would like more information, believe you have a case, or would like to speak to a member of Constantine Cannon’s whistleblower lawyer team, please contact us for a confidential consultation.

Speak Confidentially With Our Whistleblower Attorneys

Sources:

[1]

[2] Id at 1

[3]

[4]

Read Delta Air Lines Agrees to Pay $8.1M For Alleged False Claims Act Violations Related to Misuse of Pandemic Relief Funds at constantinecannon.com

By the 91pornWhistleblower Team

Last Monday (July 28), the Department of Justice (DOJ) announced that Florida-based telecommunications provider Q Link Wireless and its owner Issa Asad agreed to pay roughly $110 million to settle criminal and civil charges of violating the False Claims Act by defrauding the FCC’s Lifeline Program.¹

Q Link’s Fraud Against the Lifeline Program

The Lifeline Program provides nearly $2 billion each year to assist low-income consumers with their telecommunications needs.�� Under the program, the Government provides carriers with monthly payments for providing discounted phone services to qualified consumers.�� To be eligible to receive these Government funds, participating carriers — such as Q Link — must certify their compliance with the governing Lifeline rules, which include the requirement that they stop subsidizing customers who are not using their Lifeline phones at least once a month.

According to the Government, Q Link and Asad orchestrated a scheme of enrolling Lifeline customers who neither needed nor used their phones, including customers who never even had activated phones.�� The Government further alleged that to conceal their scheme and continue collecting payments for ineligible customers, Q Link, Asad, and others fabricated cell phone activity on behalf of Lifeline customers who were not using their phones.�� This included manufactured cell phone usage for some cell phones still in the FCC’s possession at the time of the apparent usage.

The Government claimed the scheme resulted in roughly $38.5 million in improper Lifeline payments between February 2018 and October 2019. ��As part of a global resolution of the matter, Q Link and Asad pled guilty to conspiring to commit wire fraud and theft of Government funds and defrauding the United States, with Asad to serve up to 5 years in prison.

Government Program Fraud is a False Claims Act Enforcement Policy

In announcing the resolution of the matter, the Government stressed its commitment to go after those that defraud important Government programs like the Lifeline Program.�� DOJ Civil Chief Brett Shumate underscored how the settlement “demonstrates [DOJ’s] continuing commitment to preventing fraud against important FCC subsidy programs like Lifeline.”�� US Attorney Hayden O’Byrne added that “when individuals and corporations target programs that serve vulnerable populations to line their own pockets with millions, our office stands ready to investigate and pursue those allegations using all appropriate civil enforcement tools.”

The False Claims Act is the Civil War era statute originally enacted to go after war profiteers trying to defraud the Union Army with lame mules and defective munitions.�� It has since become the Government’s main fraud-fighting tool, bringing in billions of dollars every year from those that defraud the Government.

While Medicare/Medicaid fraud accounts for the largest number of False Claims Act enforcement actions the Government brings, Government program fraud is also a priority enforcement area.�� According to 91pornwhistleblower partner Alysia Solow, “The False Claims Act covers virtually any form of fraud that results in financial loss to the Government.”�� Solow says that “when that financial loss impacts Government programs designed to support low-income or otherwise disadvantaged individuals, the Government is particularly aggressive in its enforcement approach.”

Whistleblowers Are Critical To Uncovering Government Program Fraud

The vast majority of False Claims Act actions are originated by whistleblowers under the qui tam provisions of the statute, which allow private parties to bring these cases on behalf of the Government.�� In return, successful whistleblowers may receive up to 30% of the Government’s recovery.

The Government did not indicate whether a whistleblower was involved in initiating the Q Link matter, but it’s very possible whistleblowers were involved at some point in the Government’s investigation given the complicated nature of the scheme. ��As is the case with many of the fraudulent schemes we face today, they are extremely difficult to detect without the help of those on the inside with a front-row seat to the illicit activity.

91pornHas Substantial Experience Representing False Claims Act Whistleblowers

91pornhas substantial experience representing whistleblowers under the False Claims Act.�� If you would like to learn more about our numerous whistleblower successes in this area, the type of fraud covered by the statute, 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 the 91pornwhistleblower team for a free and confidential consultation.

Speak Confidentially with Our Whistleblower Attorneys

Read Q Link Wireless Carrier To Pay $110M For Defrauding Government Program To Support Low Income Cell Phone Needs at constantinecannon.com

By the 91pornWhistleblower Team

Last week, the Department of Justice (DOJ) announced the settlement of two False Claims Act cases involving customs fraud.

DOJ Goes After Intentional Avoidance of Customs, Antidumping, and Countervailing Duties

On July 23, MGI International subsidiaries Global Plastics and Marco Polo International agreed to pay $6.8 million to settle DOJ charges that they failed to pay customs duties on plastic resin imported from China.^��1�� And on July 24, Pennsylvania patio furniture company Grosfillex Inc. agreed to pay $4.9 million to settle DOJ and whistleblower charges of evading antidumping and countervailing duties on items made of extruded aluminum originating from China.^��2

Importers must declare the country of origin of the goods they bring into the country, the value of the goods, whether the goods are subject to customs duties, and if so, how much they must pay Customs and Border Protection (CBP).�� MGI and its subsidiaries voluntarily disclosed to DOJ and CBP that since May 2019, Global Plastics and Marco Polo failed to declare the correct country of origin and value and pay the associated customs duties on certain plastic resin products they imported from China.

The Grosfillex matter involved evading antidumping and countervailing duties, which are designed to protect domestic producers from unfair foreign competition.�� Antidumping duties protect against foreign companies “dumping” products into the U.S. at below-cost prices.�� Countervailing duties offset foreign government subsidies that likewise disadvantage American sellers. ��According to the Government, Grosfillex took steps to conceal from CBP that certain furniture parts made of extruded aluminum were subject to these duties.�� For example, the company allegedly disguised the aluminum extrusions by packaging them as sham furniture kits.

Customs Fraud Remains A Top Enforcement Priority

These two settlements are just the latest in a continuing string of False Claims Act settlements involving customs fraud.�� The Government has made it very clear that going after customs fraud is a top enforcement priority.�� The Government took pains to make this clear in promoting these recent settlements, sending a strong message to importers to pay the customs duties they owe.

In announcing the MGI settlement, for example, DOJ Civil Chief Brett Shumate stressed that DOJ “will pursue those who gain an unfair trade advantage in U.S. markets, including those who knowingly evade or underpay duties owed on foreign imports.” ��Shumate was equally forceful with the Grosfillex settlement, noting how it “demonstrates [DOJ] will continue to actively pursue those who knowingly fail to pay customs duties.”�� U.S. Attorney David Metcalf went even further underscoring how the settlement “should serve as a warning that [DOJ] will use every tool available to combat fraud in international trade.”

Whistleblowers Are Critical to Uncovering Customs Fraud

One of DOJ’s primary tools in combating customs fraud is whistleblowers.�� Under the False Claims Act, whistleblowers may bring lawsuits on behalf of the Government against those committing fraud against the Government.�� The vast majority of False Claims Act cases are originated by whistleblowers.�� In fact, former Grosfillex employee Edward Wisner originated the False Claims Act case against the company and will receive a whistleblower award of roughly $1 million from the proceeds of the Government’s recovery in that case.

The MGI matter did not originate from a whistleblower False Claims Act filing.�� DOJ learned of it from the company’s voluntary disclosure of the conduct to DOJ and CBP.�� No doubt whistleblowers raised concerns internally, leading the company to investigate and take appropriate action.

91pornpartner Dan Vitelli pointed to two major takeaways from the pair of settlements.�� First, “They demonstrate that customs fraud remains a top enforcement priority for the government.”�� Second, “Whistleblowers are key to uncovering customs fraud because companies that engage in this type of misconduct often use secretive schemes only known by insiders.”

91pornRepresents Customs Fraud Whistleblowers

91pornhas substantial experience representing whistleblowers in False Claims Act cases involving customs fraud.�� In one of our more recent cases, for example, the firm represented a whistleblower alleging an auto parts distributor misclassified brake pads imported from Asia to avoid millions of dollars of��customs duties.�� The company settled that matter for $8 million with our client receiving 18.5% of the Government’s recovery.

91pornwhistleblower partner Gordon Schnell notes the firm has seen a significant uptick in whistleblowers contacting the firm regarding potential customs fraud matters: “We are seeing more customs fraud whistleblowers than ever before, no doubt from the Government’s heavy promotion of stopping this kind of misbehavior.”�� Schnell notes 91pornis poised to file several customs fraud False Claims Act matters in the coming months.

If you would like to learn more about our other whistleblower successes, customs fraud, the False Claims Act, 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 the 91pornwhistleblower team for a free and confidential consultation.

Speak Confidentially with Our Whistleblower Attorneys

Read DOJ Settles Two False Claims Act Customs Cases, Reinforcing That Customs Fraud Remains a Top Enforcement Priority at constantinecannon.com