The Treanor Law Firm provides comprehensive representation to whistleblowers seeking to report misconduct under federal and state whistleblower programs. Our extensive experience includes advising individuals on navigating the risks of criminal and civil enforcement while maximizing the benefits provided by federal whistleblower programs. Counsel at the firm brings a unique 360-degree perspective gained from years at the U.S. Department of Justice (DOJ), advising major companies on addressing whistleblower complaints, and directly representing whistleblowers. This breadth of experience allows us to effectively guide clients through the complex processes of filing whistleblower claims and managing the potential legal and personal challenges that arise.
In recent years, the federal government has expanded its whistleblower programs to encourage individuals with knowledge of wrongdoing to come forward. These programs now offer potential immunity from criminal liability, confidentiality protections, and significant financial incentives. Below are some of the major federal whistleblower programs:
Department of Justice (DOJ) Whistleblower Programs
In 2024, the DOJ launched its first whistleblower incentive programs, which are aimed at uncovering white collar criminal violations, including fraud and corruption. Separate DOJ programs provide for the non-prosecution of potential wrongdoers who come forward in certain cases and provide financial incentives to whistleblowers. Both types of programs address protections from retaliation.
Securities and Commodities Whistleblower Programs (SEC, CFTC)
Established under the Dodd-Frank Wall Street Reform and Consumer Protection Act following the 2008-09 financial crisis, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) whistleblower programs have awarded hundreds of millions of dollars to individuals who expose securities and commodities fraud and violations of the Foreign Corrupt Practices Act (FCPA). These programs incentivize individuals to report securities and commodities law violations by offering financial rewards of 10% to 30% of monetary sanctions collected in cases where their information leads to successful enforcement actions exceeding $1 million. Under these programs, whistleblowers are allowed to file complaints anonymously, protecting their confidentiality.
Treasury Department (FinCEN) AML and Sanctions Whistleblower Program
The Financial Crimes Enforcement Network (FinCEN) oversees a whistleblower program designed to combat money laundering and sanctions violations. This program provides financial rewards to individuals who report significant violations of anti-money laundering (AML) laws and economic sanctions. Whistleblowers under this program benefit from confidentiality protections and the opportunity to collaborate with enforcement agencies to uncover and address misconduct. This program offers financial rewards to individuals who report significant violations of anti-money laundering (AML) laws and economic sanctions. Awards range from 10% to 30% of monetary sanctions collected in cases where the total exceeds $1 million. The program was created by Congress in 2021 but its implementing regulations are still under development.
False Claims Act (FCA) Whistleblower Program
The False Claims Act, signed into law in 1863, is the oldest federal whistleblower statute and remains one of the most effective tools for combating fraud against the government. The FCA’s qui tam provisions allow whistleblowers (known as relators) to file lawsuits confidentially on behalf of the government and to share in the recovery of funds. Whistleblowers can receive between 15% and 30% of the government’s recovery, which can be substantial due to treble damages and civil penalties. The FCA’s broad scope applies to federal spending, procurement, and contracting, including conduct occurring outside the U.S. The program also allows non-U.S. citizens and organizations to act as whistleblowers.
IRS Whistleblower Program
The IRS whistleblower program incentivizes individuals to report significant tax fraud and underpayment of taxes. Whistleblowers who provide original information leading to the recovery of unpaid taxes may receive an award of 15% to 30% of the collected amount. This program is an essential tool in uncovering tax evasion schemes and ensuring compliance with federal tax laws.
Tailored Advocacy for Whistleblowers
The Treanor Law Firm offers a client-focused approach to whistleblower representations, addressing each client’s unique circumstances and the complexities of the relevant whistleblower programs. We provide guidance on filing claims, navigating confidentiality protections, and managing risks associated with potential enforcement actions. By leveraging our deep understanding of government enforcement priorities and processes, we help clients achieve favorable outcomes while ensuring their rights and interests are protected.