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A Focus on Multinationals: Adding Enterprise Value Through Global Whistleblower Protocols and Promoting Employer Values

Client Alert | 1 min read | 11.12.21

Whistleblower activity—including new whistleblower laws—has increased in recent years; however, the number of internal whistleblower complaints has fallen. Internal whistleblower complaints are an opportunity for employers to correct misconduct, noncompliance, or other workplace problems as they happen. While this presents a challenge for employers, it is also an opportunity to reevaluate internal policies, training, and workplace culture. In this article, the second installment of a two-part series, Director of Global Corporate Compliance for Corning, Inc., Dan Christmas, along with Crowell’s Preston Pugh, Trina Fairley-Barlow, and Rachel Lesser, discuss strategies for maximizing the benefits and minimizing the risks of increased whistleblower activity. Part one of this series, available here, reviews the rise in whistleblower bounty laws and other laws designed to incentivize reporting.

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Client Alert | 4 min read | 05.18.26

(Not) All’s Weld That Ends Weld: Duty Evasion Scheme Ends in Historic $549.5M FCA Settlement

The Department of Justice (DOJ) and the cross-agency Trade Fraud Task Force have upped the ante by an order of magnitude in the government’s pursuit of customs fraud. On May 1, 2026—only a few months after setting its previous record-high customs-related False Claims Act (FCA) settlement of $54.4 million with Ceratizit USA, LLC—the DOJ shattered that record with a $549.5 million settlement with Perfectus Aluminum Inc., its subsidiary Perfectus Aluminum Acquisitions LLC, and a set of four affiliated warehousing companies. The Perfectus settlement resolves allegations that the defendants violated the FCA by evading antidumping and countervailing duties (AD/CVD). The settlement resolves three separate qui tam complaints filed by two individual relators and the Aluminum Extruders Council, an international industry association. Defendants were previously criminally convicted on charges related to the same scheme, and those convictions were affirmed by the Ninth Circuit in 2024....

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