News & Analysis as of

False Claims Act (FCA)

Epstein Becker & Green

DOJ Civil Division Announces 2025 Priorities: Promises “Aggressive” False Claims Act Enforcement of Civil Rights Violations and...

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On June 11, 2025, Assistant Attorney General Brett A. Shumate issued an internal memorandum (the “Shumate memo”) to all Civil Division employees of the U.S. Department of Justice (“DOJ”), describing the Division’s enforcement...more

Dentons

Ep. 66 – Mid-year Compliance Check-in: Three New Enforcement Priorities to Add to Your 2025 Work Plan

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As we hit the halfway point of 2025, now is the perfect time to revisit your compliance work plan. While it’s always good practice to assess whether your organization is meeting its compliance goals, this year presents a...more

Seyfarth Shaw LLP

The False Claims Act Comes to Britain? Preparing for the ‘Failure to Prevent Fraud’ Offence

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In just a few months, the UK’s corporate criminal liability offence of Failure to Prevent Fraud (FTPF) comes into force. Modelled on the framework of the Failure to Prevent Bribery offence, FTPF imposes strict liability on...more

Mintz - Health Care Viewpoints

DOJ Civil Division Publishes Memo Outlining Trump Administration Civil Enforcement Priority Related to Health Care

In May 2025 the Department of Justice (DOJ) Criminal Division published its enforcement priorities, and the Civil Division has now followed suit with a memorandum of its own (the “Civil Division Memo”)...more

Warner Norcross + Judd

DOJ’s Civil Division Targets DEI Programs, Gender-Related Health Care and Immigration

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Following leadership changes at the Department of Justice’s (DOJ) Civil Division, Brett Shumate, recently confirmed as the assistant attorney general, issued a memorandum directing DOJ attorneys to “use [their] enforcement...more

Jackson Lewis P.C.

Enhanced AFCA Empowers Agency Fraud-Fighting, Creates Compliance Concerns for Federal Contractors and Others

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Significant revisions to the Program Fraud Civil Remedies Act of 1986 (PFCRA), now called the Administrative False Claims Act (AFCA), bolster federal agencies’ ability to address alleged fraud by expanding their authority to...more

Wiley Rein LLP

GSA Announces Expansion of “Transactional Data Reporting” Program, Reducing Compliance Obligations for GSA Schedule Contractors

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WHAT: The U.S. General Services Administration (GSA) recently announced its planned expansion of the Transactional Data Reporting (TDR) program, which will make TDR mandatory for GSA Schedule contractors whose contracts...more

A&O Shearman

Supreme Court Decision Endorses Fraudulent-Inducement Theory Under Federal Wire Fraud Statute, Resolving Circuit Split And...

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On May 22, 2025, in a significant decision that clarifies the scope of the federal wire fraud statute and resolves a circuit split, the U.S. Supreme Court upheld a pair of wire fraud convictions that had been premised on a...more

Husch Blackwell LLP

False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?

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Host Jonathan Porter welcomes to the show Husch Blackwell partner Brian Flood to discuss how newly appointed personnel in the Trump administration could impact False Claims Act (FCA) enforcement for the remainder of 2025 and...more

Foley & Lardner LLP

Be Aware of Liability for Prevailing Wage Requirements, Which Can be Significant!

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A recent case filed in the United States District Court for the Eastern District of Pennsylvania, Lipinski and Taboola v. North-East Deck & Steel Supply, Civ Action No. 5:25-cv-1467, should remind all contractors and...more

WilmerHale

DOJ Civil Division Issues Enforcement Priorities Memorandum

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On June 11, 2025, the recently confirmed Assistant Attorney General for the Civil Division, Brett Shumate, issued a memorandum directing Civil Division lawyers to prioritize investigations and enforcement actions advancing...more

ArentFox Schiff

Investigations Newsletter: DOJ Criminal Division Head Details White-Collar Enforcement Priorities and Related Policy Revisions

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DOJ Criminal Division Head Details White-Collar Enforcement Priorities and Related Policy Revisions - On June 10, the head of the US Department of Justice’s (DOJ) Criminal Division, Matthew R. Galeotti, gave a speech...more

ArentFox Schiff

FCA Enforcement & Compliance Digest — Summer 2025 False Claims Act Newsletter

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Welcome to the Summer 2025 issue of “FCA Enforcement & Compliance Digest,” our quarterly newsletter in which we compile essential updates on False Claims Act (FCA) enforcement trends, litigation, agency guidance, and...more

Morris, Manning & Martin, LLP

The Department of Justice's Criminal Division is Now Prioritizing Enforcement Related to Trade, Tariff, and Customs Fraud:...

On May 12, 2025, the U.S. Department of Justice’s (DOJ) Criminal Division released a memorandum containing the Trump Administration’s new white collar enforcement priorities. Consistent with the Administration’s heightened...more

Baker Donelson

Trade Enforcement Risks Escalate with Increasing Tariffs: What Companies Should Do to Mitigate Risk

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The increase in tariffs and export control actions by the Trump Administration has led to additional reporting and compliance obligations for companies that import and export goods. To ensure these new tariffs and rules are...more

Bradley Arant Boult Cummings LLP

PPP Loan Credits and Government Contracts: What Contractors Need to Know During Incurred Cost Reviews

As federal contractors continue to navigate the post-pandemic compliance landscape, a recurring issue has emerged in government audits and incurred cost reviews: whether and how contractors must credit the government for...more

DCI Consulting

Department of Justice Launches Civil Rights Fraud Initiative

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Federal contractors who have been waiting to find out how Executive Order (EO) 14173 would be implemented now know at least one piece of the federal government’s enforcement plan....more

Cooley LLP

DOJ Announces Priorities and Policy Updates – Including Tariff Compliance Enforcement, Expansion of Whistleblower Program

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Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s...more

Vinson & Elkins LLP

Justice Department’s “Civil Rights Fraud Initiative” Increases False Claims Act Risks Related to Alleged Discrimination

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On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum announcing the creation of the Department of Justice’s (DOJ) Civil Rights Fraud Initiative (the Initiative), which directs DOJ attorneys to utilize the...more

Hinckley Allen

Top 5 Ways to Mitigate Liability Risks When AI Goes Wrong

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As integrating artificial intelligence into corporate operations accelerates, the rapid deployment of AI tools—often driven by executive and investor pressure—has outpaced the establishment of robust governance, compliance,...more

Sheppard Mullin Richter & Hampton LLP

DOJ Civil Rights Fraud Initiative Will Use the False Claims Act to Target Antisemitism and DEI Programs

At the end of May, the Department of Justice (DOJ) announced the formation of a Civil Rights Fraud Initiative to “utilize the False Claims Act to investigate and, as appropriate, pursue claims against any recipient of federal...more

Williams Mullen

Institutions of Higher Education Face Increased Exposure to False Claims Act Violations

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On May 19, 2025, the Department of Justice announced the establishment of a Civil Rights Fraud Initiative, created to enforce the False Claims Act (FCA) “against those who defraud the United States by taking its money while...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

An Emerging Opportunity for the States to Revitalize Their State False Claims Act Enforcement

While the Trump administration replaces all of the United States Attorneys, as well as many senior-level positions at the Department of Justice, stakeholders will soon be able to evaluate civil enforcement priorities under...more

PilieroMazza PLLC

Managing Litigation Risk During the Business Lifecycle, Part 4: M&A Transactions with Government Contractors

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Transactions that involve government contracts carry a unique set of challenges. Unlike a typical merger or acquisition, deals involving government contracts require the navigation of a complex web of federal laws,...more

Robinson+Cole Health Law Diagnosis

False Claims Act Enforcement of Pharmacy Pricing & Prescribing Practices: The Walgreens Cases

The Department of Justice has launched a number of enforcement actions targeting pharmacies for alleged violations of the False Claims Act (FCA). Recently, Walgreens has been the subject of two noteworthy government...more

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