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False Claims Act Usage Continues to Rise in US Tariff Enforcement Context

In the first eight months of 2025, the US Department of Justice (DOJ) announced four significant settlements involving allegations of knowingly and improperly evading customs duties on imports under the False Claims Act...more

DOJ Memo Provides Guidance on Prohibited Discrimination Practices for Federal Contractors and Federal Funds Recipients

United States Attorney General Pam Bondi recently issued a memorandum to all federal agencies titled, “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.”...more

Relaunch of DOJ-HHS Working Group Reinforces False Claims Act Enforcement Focus in Healthcare and Life Sciences Industries

The Department of Justice (DOJ) and the Department of Health and Human Services (HHS) jointly announced the relaunch of a Working Group to enhance enforcement of the False Claims Act (FCA) across the healthcare and life...more

Ninth Circuit Holds Private Parties Can Bring Claims Against Importers Under the False Claims Act for Antidumping Duty Evasion

The United States Court of Appeals for the Ninth Circuit has issued a significant ruling with potentially far-reaching consequences for companies that import merchandise, including but not limited to those subject to...more

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

Supreme Court Paves The Way for Increased Enforcement by Rejecting “Economic Loss” Requirement for Fraud Charges, Broadening...

For the last decade and more, the federal courts have grappled with the precise parameters of the federal wire fraud statute (and analogous criminal statutes). Among other things, there has been a Circuit split for some...more

New DOJ Initiative Will Use False Claims Act to Investigate DEI Policies

The Department of Justice (DOJ) has announced its plan to employ the False Claims Act as part of the Trump Administration’s efforts to eliminate illegal diversity, equity, and inclusion (DEI) and diversity, equity, inclusion,...more

Long-Awaited DOJ Guidance on White Collar Enforcement Priorities and Policies: Key Takeaways

This guidance follows a number of Executive Orders (EOs) and other memoranda from the DOJ, including (1) the February 10, 2025 EO pausing enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, pending the...more

DOJ Memo Identifies False Claims Act and Enforcement Risks Related to Gender Transition Medication and Procedures

Attorney General (AG) Pam Bondi has issued a memorandum titled “Preventing the Mutilation of American Children” (the Memo) to select Component Heads of the Department of Justice (DOJ). Released on April 22, 2025, the Memo...more

The Second Trump Administration’s First 100 days

The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

Settlement Further Signals New Surge of Reverse False Claims Act Cases Related to Customs Fraud

The United States Department of Justice (DOJ) recently announced a significant settlement that underscores the federal government’s increasing appetite to rely on the False Claims Act to address alleged customs fraud....more

How FCPA and FCA Enforcement Could Change Under President Trump

To date, President Donald Trump has signed close to 100 Executive Orders (EOs) that signal the Trump Administration’s policies and key priorities, including objectives related to corporate crime and international trade and...more

Enforcement of President Trump’s DEI Executive Order: A Strategic Roadmap for Companies Targeted for Investigation and Enforcement

Federal agencies have been enforcing President Trump’s Executive Orders, with various federal and state government agencies mobilizing to carry out Executive Order 14173, “Ending Illegal Discrimination and Restoring...more

False Claims Act Year in Review: 2024

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

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

President Trump’s Executive Orders suggest new targets for False Claims Act enforcement

On February 21, 2025, the federal district court in Maryland issued a preliminary injunction in a case brought by the National Association of Diversity Officers in Higher Education, among others. The case challenges the...more

Federal Judge Rules Whistleblower Provision of the False Claims Act is Unconstitutional

In an eye-opening decision, a judge in the Middle District of Florida held that the unique whistleblower, or “qui tam,” provision of the federal False Claims Act (FCA) violates the Appointments Clause of Article II of the...more

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