Cybersecurity requirements for federal contractors and grantees continue to proliferate—and those requirements do not just come with contractual risk. Increasingly, the United States government is leveraging enforcement...more
9/5/2024
/ Compliance ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Data Security ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
False Claims Act (FCA) ,
False Statements ,
Federal Contractors ,
Fraud ,
Self-Certification ,
Universities ,
Whistleblowers
The government has been actively investigating and prosecuting Paycheck Protection Program (“PPP” or the “Program”) fraud ever since the Small Business Administration (“SBA”) rolled out the Program in the Spring of...more
In the Spring of 2020, the Small Business Association (“SBA”) began administering the Paycheck Protection Program (the “PPP” or the “Program”) to provide SBA-backed loans to help eligible businesses maintain their workforces...more
10/1/2021
/ Certification Requirements ,
Coronavirus/COVID-19 ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Lenders ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA ,
SBA Lending Programs ,
Small Business
On January 12, 2021, the Eastern District of California entered into a civil settlement with a Paycheck Protection Program (“PPP”) borrower and its CEO to resolve allegations of fraud. The settlement stemmed from a $350,000...more
1/15/2021
/ CARES Act ,
Chapter 11 ,
Commercial Bankruptcy ,
Criminal Prosecution ,
Enforcement Actions ,
False Claims Act (FCA) ,
FIRREA ,
Fraud ,
Paycheck Protection Program (PPP) ,
Qui Tam ,
Settlement
In what may be the beginning of a wave of enforcement actions, the Justice Department charged an organization and its leadership with dual healthcare and securities fraud charges. The prosecution underscores the risks facing...more
The Justice Department announced this week the formation of a new Procurement Collusion Strike Force, which will focus on “deterring, detecting, investigating and prosecuting antitrust crimes, such as bid-rigging conspiracies...more
11/7/2019
/ Anti-Competitive ,
Antitrust Division ,
Antitrust Violations ,
Bid Rigging ,
Department of Justice (DOJ) ,
Federal Acquisition Regulations (FAR) ,
Federal Agency Taskforce ,
Federal Contractors ,
Federal Procurement Systems ,
Fraud ,
Leniency Programs ,
Strategic Enforcement Plan ,
Subcontractors ,
Teaming Agreements
The past 18 months have been a (relatively) wild time for the False Claims Act - on the books since 1863. In FY2018 the Department of Justice obtained more than $2.8 billion in settlements and judgments from cases involving...more
8/26/2019
/ Appointments Clause ,
Article III ,
Cochise Consultancy Inc v United States ex rel Hunt ,
Cooperation ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
Materiality ,
Objective Falsity ,
Qui Tam ,
Relators ,
Separation of Powers ,
Split of Authority ,
Standing ,
Statute of Limitations ,
Tolling ,
Universal Health Services Inc v United States ex rel Escobar
Public entities at the Federal, state, and local levels set aside contracting opportunities, provide preferential price treatment, or otherwise grant favorable treatment to contractors (1) owned by veterans, women,...more
In a recent memorandum issued to Main Justice litigating components and United States Attorney’s offices nationwide, Deputy Attorney General Sally Quillan Yates emphasized that “fighting corporate fraud and other misconduct”...more
In an important decision regarding the False Claims Act’s much-litigated “public disclosure” bar, the United States Court of Appeals for the Fourth Circuit recently concluded that the disclosure of reports and audits to...more