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there is mounting frustration over these efforts and the further resulting challenge ofgetting employees to work through internal channels to address problems. Regardless,savvy corporate managers for companies in the line of fire are moving expeditiously toimprove internal reporting mechanisms and ensure that they address employeeconcerns and complaints are properly addressed.This article will survey components of the growing arsenal of tools available towhistleblowers, and, more importantly, address what has become the predominanttrigger for whistleblower controversy. The article offers practical suggestions formanaging risk based on the hard lessons learned by companies who have beenexposed to enforcement as a result of whistleblowers. While by no means an easytask, the premise of this article is that there are practical measures that can beemployed to address this risk effectively and reduce whistleblower claims and theirconsequences.I. Overview of Notable Whistleblower LawsA. The False Claims ActThe False Claims Act (“FCA”) 2 was enacted during the Civil War in an effort to combatfraud by suppliers of goods and materials to the Union Army. 3The law has beenamended various times but generally prohibits the knowing making of false claims (orcausing false claims to be made) in order to get the government to pay claims for goods2 31 U.S.C. § 3729 et seq.3 The False Claims Act-Department of Justice, A Primer (April 22, 2011),http://www.justice.gov/sites/default/files/civil/legacy/2011/04/22/C-FRAUDS_FCA_Primer.pdf.2

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