The U.S. Department of Justice (DOJ) announced on May 19, 2025, that it would use the False Claims Act (FCA) against institutions and contractors receiving federal funding that "knowingly" violate federal civil rights laws...more
The U.S. Department of Justice (DOJ or Department) announced on May 12, 2025, new investigative and policy priorities, as well as changes to current DOJ guidance, that could have a significant impact on the prosecution of...more
5/15/2025
/ Anti-Money Laundering ,
China ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Financial Crimes ,
Healthcare Fraud ,
New Guidance ,
Non-Prosecution Agreements ,
Significant Transnational Criminal Organization ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
A significant number of government contracts and grants have been terminated recently by federal agencies pursuant to the U.S. Department of Government Efficiency's (DOGE) "cost efficiency initiative" and review of "covered...more
5/8/2025
/ Contract Disputes ,
Contract Termination ,
Corporate Liability ,
Department of Government Efficiency (DOGE) ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Grants ,
Fraud ,
Risk Management ,
Settlement ,
Trump Administration ,
Whistleblowers
The U.S. Department of Justice (DOJ or the Department) has published statistics on False Claims Act (FCA) settlements and judgments for fiscal year (FY) 2024, a year in which the Department saw the highest number of qui tam...more
2/5/2025
/ Cybersecurity ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Federal Contractors ,
Government Agencies ,
Healthcare Fraud ,
PHI ,
Qui Tam ,
Whistleblowers
Whistleblower programs are the gifts that keep giving to enforcement agencies, driving a record number of cases, sanctions and awards across multiple agencies. In this ninth installment of Season's Readings, we revisit some...more
12/20/2024
/ Appointments Clause ,
Article II ,
CFTC ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Federal Pilot Programs ,
FinCEN ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more
8/28/2024
/ Compliance ,
Controlled Unclassified Information (CUI) ,
Cyber Crimes ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
False Claims Act (FCA) ,
False Statements ,
Federal Contractors ,
Fraud ,
Implied Certification ,
Internal Controls ,
Invoices ,
NIST ,
Qui Tam ,
Security and Privacy Controls ,
Universities ,
US Air Force ,
Whistleblowers
After announcing at the ABA White Collar Crime Conference last winter that it would engage in a months-long "policy sprint," the U.S. Department of Justice (DOJ or Department) released its Corporate Whistleblower Awards Pilot...more
8/6/2024
/ CFTC ,
Corruption ,
Department of Justice (DOJ) ,
Extortion ,
Federal Pilot Programs ,
Financial Institutions ,
FinCEN ,
Healthcare ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
The U.S. Department of Justice (DOJ or Department) has published statistics on False Claims Act (FCA) settlements and judgments for fiscal year (FY) 2023, noting that this was the highest number of settlements and judgments...more
The U.S. Supreme Court ruled in U.S. ex rel. Polansky that the federal government has the authority to dismiss a False Claims Act (FCA) suit at any stage of litigation, even over a relator's objections, so long as the...more
6/26/2023
/ Article II ,
Constitutional Challenges ,
False Claims Act (FCA) ,
Federal Rules of Civil Procedure ,
Judicial Intervention ,
Lack of Authority ,
Motion to Dismiss ,
Qui Tam ,
Regulatory Authority ,
Relators ,
SCOTUS ,
United States ex rel Polansky v Executive Health Resources Inc ,
Whistleblowers
The U.S. Department of Justice (DOJ) on Feb. 7, 2023, released its annual statistics for its civil False Claims Act (FCA) and fraud cases from the 2022 fiscal year (FY). Up front, we see the following key takeaways ...more
The U.S. Department of Defense (DoD), Office of the Inspector General (OIG) recently issued a report highlighting its work conducted in Fiscal Year (FY) 2018. The report provides statistics on the number of audits,...more
Companies involved in False Claims Act suits filed by qui tam relators often find themselves facing potential suspension or debarment from federal contracting. A recent decision out of the United States District Court for the...more