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DOJ Formalizes Plan to Use False Claims Act to Enforce “Civil Rights Fraud”

Key Takeaways: - The U.S. Department of Justice (“DOJ”) announced the creation of a new initiative focused on using the False Claims Act (“FCA”) to pursue “Civil Rights Fraud.” - DOJ warned FCA claims could arise when a...more

False Claim Act Liability Under Anti-Kickback Statute Requires But-For Causation: First Circuit Narrows Liability in Growing...

On February 18, 2025, the First Circuit Court of Appeals issued its decision in U.S. v. Regeneron Pharmaceuticals, ruling that the Anti-Kickback Statute (“AKS”) requires the government to prove that an AKS violation was the...more

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...more

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

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

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

Health Care Fraud Enforcement in 2025

We kick off our annual Year in Preview series with a comprehensive look at health care fraud enforcement in 2025. This post proceeds in three parts. First, we explore what the second Trump administration might bring, looking...more

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