Mr. Michael A. Sullivan
Finch McCranie LLP
Michael A. Sullivan is a former US federal prosecutor with 35+ years of experience. In addition to advising clients on compliance and performing internal investigations, he represents qui tam whistleblowers in cases under the False Claims Act, as well as SEC Whistleblowers, FCPA Whistleblowers, CFTC Whistleblowers, and IRS Whistleblowers.
He also continues to successfully try cases in complex civil litigation of many types. He also served as Counsel to the Volkswagen AG Independent Compliance Monitor and Auditor, and coordinated with counsel across the globe to satisfy legal requirements of countries in Europe, Asia, North America, and South America.
He also advises international and domestic clients on compliance with US laws, and he conducts and supervises internal investigations for clients with business integrity issues. He has also served as a Special Master appointed by a US District Court.
See https://www.finchmccranie.com/michael-a-sullivan.html.
Since the late 1980s, he has worked with the False Claims Act. He represents those who report fraud against the government or against investors. He has helped draft state versions of the False Claims Act. He is one of the first lawyers to represent clients in the IRS Whistleblower Program.
When Congress sought to create a new SEC Whistleblower program in 2010, Senate Banking Committee representatives contacted Mr. Sullivan to discuss what an effective whistleblower program must include. He has also discussed the proposed rules for the SEC and CFTC Whistleblower programs with the Chairmen and senior staff of both agencies. The final rules issued by both the SEC and CFTC incorporated important changes that he advocated. Mr. Sullivan's practice now includes representing whistleblowers in SEC Whistleblower and CFTC Whistleblower claims, including FCPA whistleblowers reporting foreign bribery and accounting violations of the Foreign Corrupt Practices Act.
Mr. Sullivan represented Relators in some of the most significant health care fraud qui tam recoveries in recent years, including (1) the $465 million settlement by Mylan, Inc. in 2017 for erroneously classifying its patented, brand name drug EpiPen as a generic drug to avoid its obligation to pay higher Medicaid rebates; and (2) the groundbreaking case that authorized use of statistical sampling to prove elements of FCA liability and damages, United States ex rel. Martin v. Life Care Centers of America, Inc. (E.D. TN), which in 2016 produced the largest health care fraud settlement in history against a skilled nursing facility chain.
His trial victories include representing a major multinational corporation in uncovering a commercial bribery and kickback scheme, and then as lead counsel winning a jury verdict of eight figures against those who perpetrated it.
Mr. Sullivan is a 1984 graduate of Vanderbilt Law School, where he was Senior Articles Editor of the Vanderbilt Law Review, and was selected for Order of the Coif. He clerked for U.S. District Judge Marvin H. Shoob in the Northern District of Georgia. He also served as a federal prosecutor in the Independent Counsel investigation of the Department of Housing and Urban Development, which included the prosecution of former Secretary of the Interior James Watt.
