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One theme stands out across federal enforcement when looking back on the 2025 landscape: whistleblowers remain among the most powerful tools the United States has to combat fraud, corruption, and corporate misconduct. From healthcare and pharmaceuticals to tax evasion and securities violations, whistleblower disclosures were central to some of the largest government recoveries of the year.
Taken together, the top whistleblower-driven settlements of 2025 reflect both familiar patterns and emerging shifts in enforcement priorities. In this Sunday Read, National Whistleblower Center (NWC) will revisit some of last year’s top resolutions and explore the important questions they raise about incentives, confidentiality, and the future of whistleblower programs in the U.S. and abroad.
False Claims Act for Healthcare and Pharmaceuticals Still Dominate
Healthcare fraud topped the list with a $1.64 billion judgment against Johnson & Johnson’s Janssen unit rendered in March 2025 by U.S. District Judge Zahid N. Quarashi of the District of New Jersey. The case stemmed from two whistleblowers’ allegations of unlawful HIV drug marketing and false claims submitted to federal healthcare programs. The whistleblowers were former Janssen sales representatives who filed claims 12 years prior, and their actions underscored the continued effectiveness of the False Claims Act (FCA) in policing misconduct tied to Medicare and Medicaid spending.
Another notable result was Gilead Sciences’ $202 million settlement with the Department of Justice (DOJ). Announced in April 2025, the settlement resolving allegations that the company paid kickbacks to physicians, resulting in improper government reimbursements.
Health and Human Services-Office of the Inspector General’s Special Agent in Charge Naomi Gruchacz said: “This impactful settlement is the result of collaborative work by law enforcement partners, revealing Gilead’s unlawful practice of providing kickbacks to physicians under the guise of its HIV educational speaker programs. Violations of the Anti-Kickback Statute, which in this case involved expensive HIV medications, can inappropriately influence physicians’ decision-making and divert the monies of taxpayer-funded federal healthcare programs.”
As with many FCA cases, insiders with access to internal sales and compliance information played a critical role in bringing the conduct to light.
“These cases reflect a longstanding trend,” noted Stephen M. Kohn, NWC Co-Founder and Chairman of the Board. “Healthcare remains one of the most fertile areas for whistleblower enforcement due to the complexity of reimbursement systems and the vast sums of taxpayer dollars at stake.”
Beyond the headline-grabbing announcements, 2025 saw a steady stream of mid-level FCA settlements, including hospital systems, government contractors, and PPP loan misuse cases, many resolving in the $5-to-$50 million range. In several instances, whistleblowers received multimillion-dollar awards, such as a $6.5 million relator share from a $36 million Medicare fraud settlement.
These cases may attract less public attention, but collectively they represent billions in recoveries and demonstrate how whistleblowers function as force multipliers for enforcement agencies stretched thin by limited resources.
Tax Whistleblowers and Cross-Border Enforcement
One of the most consequential whistleblower developments of 2025 came from tax enforcement. Whistleblowers connected to the long-running Credit Suisse and UBS investigations are expected to share up to $150 million from a $511 million DOJ and IRS settlement involving offshore tax evasion.
This case highlighted the unique power of the IRS Whistleblower Program, which allows insiders—often bankers, accountants, or compliance professionals—to expose sophisticated schemes that deprive governments of massive tax revenues. It also illustrates the increasingly global nature of whistleblowing, as information originating overseas leads to U.S. enforcement actions with worldwide impact.
In its calls for reforms to the IRS Whistleblower Program, NWC has emphasized that tax whistleblower rewards are essential to combating illicit financial flows. The Credit Suisse matter reinforces that message.
Securities Fraud and SEC’s Downward Trend
The U.S. Securities and Exchange Commission (SEC)’s Whistleblower Program also delivered meaningful results in 2025. The Commission announced multiple awards throughout the year, including more than $6 million paid to joint whistleblowers whose tips led to successful enforcement actions.
However, the dollar figures were substantially smaller than healthcare or tax recoveries – both in the number of awards and their collective value. As noted by Whistleblower Network News, SEC whistleblower awards for the 2025 fiscal year (Oct. 1, 2024 to Sept. 30, 2025) demonstrate an alarming drop in whistleblower compensation, as demonstrated by the award orders published by the SEC.
Aside from 122 denials and six orders omitting award amounts, award orders for fiscal year (FY) 2025 total $59.7 million. This figure averages to around $2 million per award. The 2025 report stands in stark contrast to (FY) 2024 and (FY) 2023, which had totals of $255 million and $600 million, respectively. The SEC’s whistleblower program has not seen such a low level of awards since 2017 under the Obama administration.
Kohn said the sharp drop was concerning, and hopes it does not mark the start of an annual trend.
“The numbers and history do not lie,” Kohn said. “Whistleblowers’ actions have retained and recovered billions of dollars. Hopefully, such a difference between 2025 and prior years only is an exception and will not become the rule. All administrations should prioritize the incentivization of whistleblowers.”
Policy Implications: Incentives Matter
Though not every year yields record-breaking numbers, the 2025 settlement landscape reinforces a central policy lesson that whistleblower incentives still work. Programs that provide clear, mandatory rewards and strong confidentiality protections continue to outperform systems that rely solely on moral appeals or retaliation remedies.
Concurrently, disparities across programs remain stark. While the FCA, IRS, and SEC frameworks have produced consistent results, other jurisdictions—and even some U.S. regulatory regimes—still lack comparable incentive structures. As countries like the UK begin experimenting with whistleblower rewards, the U.S. experience in 2025 offers a powerful example of what effective enforcement looks like.
“For policymakers, the message is clear: Protect whistleblowers. Reward them when their information leads to success,” Kohn said. “And recognize that accountability, when properly incentivized, pays dividends far beyond any single settlement.”
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For Whistleblowers Seeking Representation
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This article was written by Justin Smulison, a professional writer, podcaster, and event host based in New York.
