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DOJ’s Brenna Jenny Comments on Priorities for FCA Enforcement

On January 28, 2026, Brenna Jenny, Deputy Assistant Attorney General for the Commercial Litigation Branch of the Department of Justice’s Civil Division, delivered comments to False Claims Act (“FCA”) practitioners about DOJ’s...more

DOJ’s Annual Report and Civil Fraud Leadership Suggests FCA Cases Will Dominate 2026 Enforcement Efforts

The Department of Justice (“DOJ”) recently released its 2025 statistics for federal False Claims Act cases. With settlements and judgments exceeding $6.8 billion last year, DOJ’s report shows that the False Claims Act (“FCA”)...more

DOJ’s Annual Report Suggests FCA Cases—Especially Qui Tam Cases—Will Continue to Surge in 2026

The Department of Justice (“DOJ”) recently released its 2025 statistics for federal False Claims Act cases. With settlements and judgments exceeding $6.8 billion last year, DOJ’s report shows that the False Claims Act (“FCA”)...more

Civil Rights Fraud Investigations of DEI Programs Have Begun

On May 19, 2025, the Department of Justice (“DOJ”) announced its Civil Rights Fraud Initiative (the “CRFI”). As discussed in our post related to that announcement, the CRFI mobilizes federal, state, and local law enforcement...more

DOJ Poised to Reboot FCPA Investigations and Enforcement

Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more

DOJ’s Plan to Use the False Claims Act to Address Civil Rights Fraud

According to a memorandum issued on May 19, 2025, the Department of Justice (“DOJ”) will use the False Claims Act as a tool to enforce federal civil rights laws. The new policy memo has serious potential implications for...more

New Executive Order Directs DOJ to Pause FCPA Enforcement

On February 10, 2025, President Trump issued an executive order that instructed DOJ to pause all action related to enforcement of the Foreign Corrupt Practices Act (FCPA). Enacted in 1977, the FCPA features anti-bribery...more

Supreme Court Rejects an Objective Standard for False Claims Act Inquiries

The False Claims Act imposes liability for false and fraudulent claims a defendant submitted with the requisite state of mind, or scienter. Before the Supreme Court handed down its June 1, 2023, decision in the combined...more

"Varsity Blues" Reversal Demonstrates Limitations of Conspiracy Allegations

On May 10, 2023, the First Circuit dealt a major blow to the Department of Justice’s wide-ranging "Varsity Blues" investigation by reversing convictions of two defendants. Individuals, companies, and federal contractors in...more

Recent Actions Illustrate Continued Focus on Export Control Violations

Last week, Deputy Attorney General Lisa Monaco’s statements to the American Bar Association again highlighted the fact that investigating and prosecuting individuals for violating economic sanctions, export controls, and...more

DOJ's New Policies Encourage Voluntary Self-Disclosure, Compensation Tied to Compliance

In a speech given at NYU on September 15, 2022, Deputy Attorney General Lisa Monaco reviewed new and enhanced Department of Justice (DOJ) policies regarding criminal enforcement related to corporate entities. Assistant...more

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