The US Court of Appeals for the First Circuit’s landmark decision in United States v. Regeneron Pharmaceuticals will have some implications for healthcare compliance and defense strategies. In the case, the First Circuit...more
As we discussed in this April 7 blog post, the US Department of Justice (DOJ) can pursue civil penalties for tariff evasion under the False Claims Act (FCA), including against companies that are aware of tariff evasion by...more
On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 (IEEPA) to announce a sweeping new tariff regime, with a 10%...more
4/8/2025
/ Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Supply Chain ,
Tariffs ,
Trump Administration ,
Whistleblowers
With both the False Claims Act and the Administrative False Claims Act now part of the federal arsenal, companies dealing with US government funds can expect to see increased scrutiny of alleged false claims by the Department...more
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
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
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
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