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False Claims Act (FCA) Whistleblowers Compliance

McCarter & English Blog: Government Contracts...

Through the Looking Glass: Shifting DEI Standards Expose Contractors to False Claims Act Risk

There is a growing sense of confusion and unease among many federal contractors and grant recipients in these early days of the second Trump administration. In a time when some agencies face dislocation and downsizing (or, as...more

Epstein Becker & Green

#WorkforceWednesday®: Federal Contractors Alert - DEI Restrictions Reinstated by Appeals Court - Employment Law This Week®

Epstein Becker & Green on

This week, we’re focused on federal contractors and the effects that the reinstatement of Executive Orders 14151 and 14173 will have on employers: President Trump’s executive orders against diversity, equity, and inclusion...more

Cozen O'Connor

Texas AG Settles for $40 Million Over Medicaid Fraud Allegations

Cozen O'Connor on

Texas AG Ken Paxon announced a settlement with Molina Healthcare of Texas, Inc. and Molina Healthcare, Inc. (collectively, “Molina”), to resolve allegations of Medicaid fraud. The AG’s office claims Molina violated the Texas...more

ArentFox Schiff

Investigations Newsletter: FCA Enforcement & Compliance Digest — Winter 2025 False Claims Act Newsletter

ArentFox Schiff on

Welcome to the Winter 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

DLA Piper

False Claims Act Year in Review: 2024

DLA Piper on

The US government and private plaintiffs use the False Claims Act (FCA) – a federal statute originally enacted in 1863 in response to defense contractor fraud during the American Civil War – to combat various forms of fraud...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump...

Foley & Lardner LLP on

On February 20, 2025, the Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice (DOJ), Michael Granston, emphasized using the False Claims Act (FCA) to address U.S. Customs &...more

McCarter & English Blog: Government Contracts...

Whisper Through the Screams: DOJ Commits to False Claims Act Enforcement in 2025

Amid the chaos of the past few weeks—sweeping executive orders, relentless cost-cutting, and an air of uncertainty that lingers like smoke after a fire—federal contractors have been left reeling, straining to hear what comes...more

Benesch

A Survey of Recent Enforcement Actions, Trends & Priorities

Benesch on

The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more

Paul Hastings LLP

Federal Contractors With DEI Policies at Increased Risk of False Claims Act Liability

Paul Hastings LLP on

President Donald Trump has signed more than 60 executive orders since taking office, including Executive Order 14173, titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (EO 14173 or the Executive...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Will the CFTC’s New Top Cop Usher in an Era of Increased Investigation and Related Rewards for Whistleblowers?

On February 14, 2025, the Commodity Futures Trading Commission (CFTC) signaled some “love” for whistleblowers and the future of the CFTC’s whistleblower program when announcing that Brian Young had been appointed as a new...more

Kelley Drye & Warren LLP

New DEI Executive Order Signals New Potential Enforcement of The False Claims Act

President Trump recently issued Executive Order 14173 titled ​“Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (“Order”). The Order broadly aims to eliminate diversity, equity, and inclusion (“DEI”)...more

Baker Donelson

First Circuit Requires But-For Causation for FCA Liability Based on AKS Violations

Baker Donelson on

Key Takeaways - The First Circuit ruled in United States v. Regeneron Pharmaceuticals, Inc., that the government must prove but-for causation to establish False Claims Act (FCA) liability based on violations of the...more

Morgan Lewis

US Administration Tariff Expansion, Potential False Claims Act Actions, and Other Enforcement Implications

Morgan Lewis on

With the second Trump administration holding the reins of the executive branch, companies should brace for a renewed focus on trade enforcement. The administration has already begun to expand tariffs on a variety of items...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Hidden Dangers Lurking in Corporate Integrity Agreements

When I litigated False Claims Act (FCA) cases at the U.S. Department of Justice (DOJ), it was common practice for settlements to require Corporate Integrity Agreements (CIAs) setting forth ongoing duties and responsibilities...more

Bass, Berry & Sims PLC

Fourth Circuit Holds that Violation of CIA Can Support Reverse False Claims and Adopts Relaxed Rule 9(b) Presentment Requirement

Bass, Berry & Sims PLC on

On February 3, the U.S. Court of Appeals for the Fourth Circuit reversed a district court’s grant of a motion to dismiss, holding in relevant part that: - Violations of a Corporate Integrity Agreement (CIA) can create an...more

Davis Wright Tremaine LLP

New Administration Outlook: What Should Federal Contractors Do With Their DEI Programs?

Recipients of federal funding now have broad mandates but little guidance from the Trump Administration about employer DEI programs. Trump's new Executive Order "Ending Illegal Discrimination and Restoring Merit-Based...more

Mintz - Employment Viewpoints

The False Claims Act and President Trump’s DEI Executive Order: Federal Contractor Employers Must Take Notice

In the wake of President Trump’s “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” Executive Order (the “Executive Order”) (discussed further here), many companies are in the process of revisiting their...more

Morrison & Foerster LLP - Government...

President Trump’s DEI Certification for Federal Contractors Creates Significant FCA Risk

On January 21, 2025, President Trump signed an executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (the “Order”), rescinding affirmative action under Executive Order 11246 and other...more

Bradley Arant Boult Cummings LLP

The False Claims Act in 2024: A Government Enforcement Update

This past year, the False Claims Act (FCA) continued to be a key tool for the Justice Department and whistleblowers to bring suits against companies, including those in the financial services sector. The Justice Department...more

Bradley Arant Boult Cummings LLP

More Whistleblower Suits Filed Than Ever Before: The False Claims Act in 2024

As in recent years, the False Claims Act (FCA) continued to serve as a tool utilized by the federal government against government contractors in 2024. The government collected more than $2.9 billion as a result of 558 FCA...more

Foley Hoag LLP

Understanding the False Claims Act Implications of President Trump’s Diversity, Equity, and Inclusion-related Executive Orders

Foley Hoag LLP on

I. Scope of Executive Order 14173 - Executive Order 14173, issued on January 21, 2025, aims to end illegal discrimination and restore merit-based opportunities by ceasing diversity, equity, and inclusion (DEI) policies,...more

Bradley Arant Boult Cummings LLP

Looking Back at the False Claims Act in 2024 as the Government Keeps its Sights on Cybersecurity in 2025

In 2024, the government and whistleblowers were party to 558 settlements and judgments collecting over $2.9 billion. The government continued its effort to combat cybersecurity threats through its Civil Cyber-Fraud...more

Bradley Arant Boult Cummings LLP

The False Claims Act in 2024: A Year in Review

In 2024, the government and whistleblowers were party to 558 False Claims Act (FCA) settlements and judgments, just slightly fewer cases than last year’s record. As a result, collections under the FCA exceeded $2.9 billion,...more

Ropes & Gray LLP

Customs Fraud May Bring a New Wave of False Claims Act Cases

Ropes & Gray LLP on

On February 1, 2025, President Trump imposed 25% tariffs on most imports from Canada and Mexico, as well as 10% tariffs on Canadian energy products and imports from China. The primary immediate impact of the new tariffs will...more

Venable LLP

Defense Contractor Resolves DOJ and SEC FCPA, FCA, Export Controls Violations for $950 Million

Venable LLP on

In October 2024, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced settlements with Raytheon Company, a division of multinational defense contractor RTX, over defective pricing and...more

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