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DOJ Civil Division Assistant Attorney General’s first day memorandum sets out FCA enforcement priorities aligned with Trump...

On the day he was sworn in, June 11, 2025, Civil Division Assistant Attorney General (AAG) Brett Shumate took the unusual step of issuing a memorandum to all employees of the Department of Justice (DOJ) Civil Division – most...more

Deputy Attorney General launches Civil Rights Fraud Initiative to pursue FCA cases based on alleged discrimination

On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum (Blanche Memorandum) directing the Department of Justice’s Civil Division Fraud Section and Civil Rights Division to lead a Civil Rights Fraud...more

First Circuit upholds but-for causation standard for False Claims Act cases premised on Anti-Kickback Statute violations

On February 18, 2025, the First Circuit joined a growing list of circuit courts to hold that “but-for causation” is the correct causation standard in most False Claims Act (FCA) cases premised on alleged violations of the...more

The False Claims Act Guide: 2022 and the road ahead - Looking Ahead

2022 was an interesting year in False Claims Act (FCA) enforcement and case law developments – from uncertainty emanating from escalating circuit splits to low recoveries for the Department of Justice (DOJ). Looking ahead,...more

The False Claims Act Guide: 2022 and the road ahead - Executive summary

In 2022, False Claims Act (FCA) settlements and judgments totaled US$2.2 billion. Although this was one of the lowest annual recovery totals in years, there is no indication that the Department of Justice (DOJ) is slowing its...more

The False Claims Act Guide: 2021 and the road ahead

In the latest edition of our False Claims Act Guide: 2021 and the road ahead, we analyze the key developments from 2021 and discuss how the most important cases and issues are shaping FCA enforcement now and in the year to...more

Roadmap for False Claims Act enforcement in 2020

Government recoveries under False Claims Act (FCA) enforcement grew slightly in fiscal year (FY) 2019 to just over $3 billion. Companies operating in the Aerospace, Defense, and Government Services (ADG) industry continue...more

DOJ issues new guidance regarding cooperation in False Claims Act investigations

Continuing its recent trend of revising and issuing new white collar enforcement guidance, the U.S. Department of Justice (DOJ) on Tuesday announced a new policy governing when cooperation credit should be given to the...more

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