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Tariffs Take Hold Raising the Specter of Criminal and Civil Tariff Enforcement

Seven months into President Donald Trump’s second administration, a new trade paradigm is emerging that presents challenges for everyone involved in bringing products into the United States. ...more

DOJ and HHS Announce New False Claims Act Working Group

On July 2, 2025, the Department of Justice (“DOJ”) and the Department of Health and Human Services (“HHS”) announced a joint DOJ-HHS False Claims Act Working Group (the “Working Group”) that will focus on enhanced enforcement...more

First Circuit Adopts “But For” Causation Standard under the Anti-Kickback Statute, Paving the Way for Potential Supreme Court...

Last week, the First Circuit Court of Appeals issued its long-awaited decision in United States v. Regeneron Pharmaceuticals with significant implications for health care companies facing allegations of violations of the...more

FCA Enforcement Priorities in the Biden Administration

During a question-and-answer session following his opening remarks at the Federal Bar Association Qui Tam Conference earlier this year, Senator Chuck Grassley said that the government needed to “come down with a sledgehammer,...more

False Claims Act: 2020 Year-in-Review

The Department of Justice (DOJ) announced on January 14, 2021 that it had recovered $2.2 billion in False Claims Act (FCA) settlements and judgments in its 2020 fiscal year. While that figure is down considerably from prior...more

COVID-19: What History Tells Us About the Importance of the False Claims Act in a Time of Pandemic

This is the first in a series of client alerts addressing the likely role of the False Claims Act in the wake of the massive federal government response to the COVID-19 pandemic. On March 20, 2020, the Department of...more

False Claims Act: 2015 Year-in-Review

In 2015, the Justice Department (DOJ) continued to give high priority to False Claims Act (FCA) investigations, bringing in nearly $3.6 billion in settlements and judgments. More than 630 qui tam suits were filed. DOJ's...more

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