Aerospace & Defense Insights: Roadmap for False Claims Act enforcement in 2022

Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in front of issues before they become problems, and seize opportunities in a timely manner. The Federal Government recovered more than $5.6 billion in fiscal year (FY) 2021 from investigations and cases involving the False Claims Act (FCA). This is more than double the $2.2 billion recovered in FY 2020 and a sharp increase from the $3 billion recovered in FY 2019. With clear signals coming from the Biden administration that they intend to aggressively employ the FCA to combat fraud, and in particular will use it to enforce cybersecurity obligations, we expect aggressive FCA enforcement to continue. Below, we examine recent enforcement trends in the A&D industry sector and key FCA-related case law developments that could affect your business.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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