On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more
The recent amendment to the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) of the Department of Justice’s (DOJ’s) Criminal Division expects companies to self-disclose allegations of misconduct within 120...more
On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more
Through ADG Insights, we share with you the top legal and political issues affecting the Aerospace, Defense, and Government Services (ADG) industry. Our ADG industry team monitors the latest developments to help our clients...more
11/22/2019
/ Aerospace ,
Cybersecurity ,
Defense Sector ,
False Claims Act (FCA) ,
Federal Contractors ,
NIST ,
Pricing Requirements ,
Qui Tam ,
Risk Management ,
Supply Chain ,
Whistleblowers
More than two years after the Northern District of Alabama granted summary judgment in a False Claims Act (FCA) case in favor of AseraCare Inc., holding that “contradiction based on clinical judgment or opinion alone cannot...more
9/11/2019
/ Bifurcation ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
False-Certification of Conformance ,
Health Care Providers ,
Healthcare Fraud ,
Hospice ,
Insurance Fraud ,
Life Sciences ,
Medicare ,
Physicians ,
Qui Tam ,
Remand ,
Terminal Illness Treatments ,
Vacated ,
Whistleblowers
The pace of False Claims Act (FCA) litigation remained furious over the past year. Companies (and individuals) in all sectors of the economy continue to face the ever-present threat of FCA enforcement whenever they do...more
1/22/2019
/ Department of Justice (DOJ) ,
Digital Realty Trust Inc v Somers ,
Enforcement Actions ,
False Claims Act (FCA) ,
False Implied Certification Theory ,
Fraud ,
Health Information Technologies ,
Implied Certification ,
Materiality ,
Qui Tam ,
SCOTUS ,
Settlement Agreements ,
Universal Health Services Inc v United States ex rel Escobar ,
US Trade Policies ,
Whistleblowers
The False Claims Act, 31 U.S.C. §§ 3729-3733, continues to pose unique liability risk for aerospace, defense, and government services (ADG) companies that directly or indirectly conduct business with the U.S. Government. In...more
4/18/2017
/ Aerospace ,
Ambiguous ,
Civil Monetary Penalty ,
Defense Sector ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
False Implied Certification Theory ,
Federal Contractors ,
Materiality ,
Qui Tam ,
Statistical Sampling ,
Successor Liability ,
Trump Administration ,
Veto Rights ,
Whistleblowers