Sam Brown, a partner at Phillips & Cohen, represents clients in False Claims Act cases and whistleblower claims with the Financial Crimes Enforcement Network, the Securities and Exchange Commission, the Commodity Futures Trading Commission, and the IRS.
His Medicare and Medicaid fraud qui tam cases have involved kickbacks, medically unnecessary services and fraudulent billing, as well as fraud by Medicare Advantage plans. He assisted in a recent False Claims Act case that resulted in a $13 million settlement.
He has helped whistleblowers report violations of the Bank Secrecy Act and U.S. sanctions laws to FinCEN through the Treasury Department’s new AML whistleblower program.
Mr. Brown also has worked on whistleblower claims made to the SEC alleging fraud and manipulation in the cryptocurrency market, false and misleading disclosures, accounting fraud, offering fraud, the sale of unregistered securities and breaches of fiduciary duty by investment advisers. He recently assisted in securing a client a $1.25 million SEC whistleblower award.
His CFTC whistleblower cases include one alleging manipulation of commodity futures prices that resulted in a successful enforcement action. He also has experience handling CFTC whistleblower cases involving spoofing and other abuses in the futures markets, manipulation in foreign exchange and oil and gas markets, as well as violations related to carbon credits, cryptocurrencies, and swaps.
In addition, he has helped IRS whistleblowers bring cases where fraudulent transfers and shell companies were used to conceal both personal and corporate income.
Mr. Brown graduated magna cum laude from the University of Michigan Law School, where he was an executive editor of the University of Michigan Journal of Law Reform. After earning his law degree, he clerked for Judge Julian Abele Cook Jr. in the US District Court for the Eastern District of Michigan for two years.
He then joined Appellate Advocates, a nonprofit public defender organization that represents indigent defendants in New York City in their appeals of criminal convictions. He was a staff attorney for three years, representing clients in all aspects of appellate litigation and winning significant victories.
Mr. Brown worked for Phillips & Cohen prior to receiving his law degree. As a summer associate, he handled various aspects of whistleblower cases. He also was a paralegal at the firm for a year, working on pharmaceutical fraud and securities fraud matters.
He is admitted to the bar in Washington, DC, and New York.
“Protect Whistle-Blowers,” The New York Times, June 18, 2024.
- “Government Whistleblower and Compliance Programs Share Same Goals,” Bloomberg Law, July 12, 2024.