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DOJ to Launch New Whistleblower Rewards Program

On March 7, 2024, US Deputy Attorney General Lisa Monaco announced a new program that will financially reward whistleblowers who notify the Department of Justice (DOJ) of “significant” corporate misconduct. This announcement...more

Supreme Court Rules FCA Liability Turns on Subjective Belief, Not Objective Reasonableness

Key takeaways - The US Supreme Court held that for the scienter element of the False Claims Act (FCA), what matters is the defendant’s “knowledge and subjective beliefs” – not objective reasonableness...more

Are Courts Reining in Causation and Remuneration in False Claims Act and Anti-Kickback Cases?

In US ex rel. Martin v. Hathaway, the US Court of Appeals for the Sixth Circuit joined the US Court of Appeals for the Eighth Circuit in requiring False Claims Act (FCA) plaintiffs to establish a direct causal relationship...more

When the Whistle Blows, Listen Carefully – and Consider Self-Disclosure

On February 22, 2023, the US Department of Justice announced a new voluntary self-disclosure policy for corporate criminal enforcement in US attorney’s offices nationwide. The policy offers concrete and meaningful incentives...more

US Supreme Court to Review Department of Justice Dismissal Authority

On June 21, 2022, the Supreme Court agreed to review a US Court of Appeals for the Third Circuit decision holding that the federal government’s ability to dismiss False Claims Act (FCA) lawsuits is controlled by Federal Rule...more

DOJ’s Pandemic Fraud Enforcement Efforts Accelerating

On March 10, 2022, the Department of Justice announced the appointment of Associate Deputy Attorney General Kevin Chambers to serve as the DOJ’s first Director for COVID-19 Fraud Enforcement. This announcement comes two years...more

Whistleblower Complaints and Rewards Explode Worldwide

What you need to know Since the onset of the COVID-19 pandemic, the number of whistleblower complaints received by regulators has exploded on both sides of the Atlantic. On November 15, 2021, the US Securities and Exchange...more

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