News & Analysis as of

False Claims Act (FCA) Department of Justice (DOJ)

Jackson Lewis P.C.

DOJ Civil Rights Fraud Initiative Ups FCA Risks for Federal Fund Recipients Employing Unlawful DEI Programs

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U.S. Deputy Attorney General Todd Blanche issued a memorandum introducing the “Civil Rights Fraud Initiative” on May 19, 2025. The memorandum directs all Department of Justice (DOJ) attorneys to use the False Claims Act (FCA)...more

Wiley Rein LLP

Supreme Court Decision Could Galvanize Prosecutions of Government Contractors

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The U.S. Supreme Court’s May 22 decision in Kousisis v. United States could have wide-ranging implications for criminal and civil fraud cases against government contractors going forward. The Court ruled that a government...more

Vorys, Sater, Seymour and Pease LLP

False Claims Act Reimagined: DOJ Pursues Civil Rights Fraud in Higher Education and Government Contracts

On May 19, 2025, the U.S. Department of Justice (DOJ) unveiled the Civil Rights Fraud Initiative, a new enforcement strategy aimed at leveraging the False Claims Act to hold colleges, universities, government contractors, and...more

Wiley Rein LLP

DOJ Civil Rights Fraud Initiative Targets "Illegal DEI" Programs via the False Claims Act

Wiley Rein LLP on

The U.S. Department of Justice (DOJ) announced the creation of the Civil Rights Fraud Initiative in a Memorandum issued on May 19, 2025. According to the Memorandum, the Initiative is an enforcement effort that will use the...more

The Volkov Law Group

False Claims and Trade Compliance: Enforcement Examples (Part III of III)

The Volkov Law Group on

In the prior post, I cited three significant risk areas for False Claims Act (“FCA”) risks and trade compliance: (1) Valuation; (2) Misclassification and (3) Country of Origin. On April 18, 2025, the United States filed a...more

Mayer Brown

New Targets, New Tactics: DOJ Whistleblower Program Focuses on Immigration Enforcement

Mayer Brown on

A new US Department of Justice (DOJ) policy, outlined in a memorandum titled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” signals increased scrutiny and an expanded enforcement focus of potential...more

Proskauer - Health Care Law Brief

DOJ’s Civil Rights Fraud Initiative: Key Considerations for Health Care Providers

The Department of Justice’s (“DOJ”) May 19, 2025 “Civil Rights Fraud Initiative” memorandum, issued by Deputy Attorney General Todd Blanche (the “Initiative”), marks a consequential policy shift for False Claims Act (“FCA”)...more

The Volkov Law Group

A Dangerous Combination: False Claims Act and Trade Violations (Part II of III)

The Volkov Law Group on

As in every Administration, the Trump Department of Justice has made clear its enforcement priorities — government fraud, immigration and national security to include tariff and trade violations.  DOJ fully recognizes the...more

Stevens & Lee

Does Your DEI Program Violate the False Claims Act?

Stevens & Lee on

On May 19, 2025, the DOJ announced the establishment of the “Civil Rights Fraud Initiative,” which seeks to use the False Claims Act (FCA) to investigate, and possibly take civil action against, recipients of federal funds...more

Blank Rome LLP

Department of Justice Announces New Initiative to Combat Civil Rights Fraud Using the False Claims Act

Blank Rome LLP on

From time to time, the Department of Justice (“DOJ”) has established initiatives, task forces, or strike teams to advance its enforcement priorities. In recent years, DOJ has announced a Procurement Collusion Strike Force, a...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Recent False Claims Act Settlement Should Put Treatment Centers on Notice

Late last month, the federal government announced a False Claims Act settlement with Summit BHC New Jersey, LLC, d/b/a Seabrook (“Seabrook”), a prominent New Jersey Drug & Alcohol Rehabilitation facility. The joint settlement...more

Holland & Knight LLP

Civil Rights Laws and False Claims Act: What Colleges and Universities Need to Know Now

Holland & Knight LLP on

The U.S. Department of Justice (DOJ) announced on May 19, 2025, that it would use the False Claims Act (FCA) against institutions and contractors receiving federal funding that "knowingly" violate federal civil rights laws...more

Alston & Bird

DOJ Settles Another False Claims Act Case for Alleged Failures in Implementing NIST SP 800-171 and Basic Cybersecurity Controls

Alston & Bird on

On May 1, 2025, the U.S. Department of Justice (DOJ) announced a settlement under the False Claims Act (FCA) involving defense contractors Raytheon Company (Raytheon), RTX Corporation (RTX), and Nightwing Group—the successor...more

Arnall Golden Gregory LLP

Government Investigations Team Insights - May 2025

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

Polsinelli

DOJ Announces Intent to Use False Claims Act To Target Diversity and DEI Initiatives

Polsinelli on

At a Glance The Department of Justice (DOJ) will use the False Claims Act (FCA) to investigate and pursue claims against entities that violate federal civil rights laws, including anti-discrimination and equal employment...more

Baker Donelson

Supreme Court Endorses "Fraudulent Inducement Theory": How the Kousisis v. United States Ruling Widens the Road for Fraud...

Baker Donelson on

If a defendant uses material misrepresentations to induce a party to enter a contract, but does not economically harm the induced party, has the defendant committed fraud? The Supreme Court has decided: Yes. On May 22, 2025,...more

The Volkov Law Group

DOJ Applies False Claims Act to Tariff and Trade Violations (Part I of III)

The Volkov Law Group on

Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs. Corporate leaders and compliance officials are making a serious...more

A&O Shearman

DOJ Announces Civil Rights Fraud Initiative Targeting Federal Fund Recipients’ Use Of DEI

A&O Shearman on

On May 19, 2025, the Department of Justice (“DOJ”) announced its plan to use the False Claims Act to investigate and pursue claims of civil rights violations against federal fund recipients. The plan, entitled the Civil...more

Bradley Arant Boult Cummings LLP

Customs Fraud Investigations Will Be a DOJ Area of Focus

On May 12, 2025, Department of Justice (DOJ) Criminal Chief Matthew Galeotti issued a memorandum addressing the “Fight Against White-Collar Crime.” The memorandum lists several priorities for white-collar criminal...more

Ropes & Gray LLP

CMS Announces Significant Changes to RADV Auditing Efforts: Considerations and Next Steps for the Medicare Advantage Industry

Ropes & Gray LLP on

On May 21, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced plans to substantially increase both the pace and the scale of Risk Adjustment Data Validation (“RADV”) audits of the Medicare Advantage (“MA”)...more

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

Latham & Watkins LLP

Key Insights on DOJ's Civil Rights Fraud Initiative

Latham & Watkins LLP on

In a memorandum dated May 19, 2025, Deputy Attorney General Todd Blanche announced the establishment of a new Civil Rights Fraud Initiative (the Initiative) at the Department of Justice (DOJ)....more

Foley & Lardner LLP

Another FCA Cybersecurity Settlement Reinforces the Enforcement Trend

Foley & Lardner LLP on

A recent United States Department of Justice (DOJ) announcement highlights the fact that the government’s emphasis on cybersecurity enforcement under the False Claims Act (FCA) is not slowing down. According to the press...more

Carlton Fields

DOJ Forms Civil Rights Fraud Initiative: A New Branch of False Claims Act Enforcement

Carlton Fields on

On May 19, 2025, U.S. Deputy Attorney General Todd Blanche announced the formation of a Civil Rights Fraud Initiative “to investigate and, as appropriate, pursue claims against any recipient of federal funds that knowingly...more

Hahn Loeser & Parks LLP

DOJ Civil Rights Fraud Initiative Set to Target Federal Government Contractors and Grantees

The U.S. Department of Justice (DOJ) launched the Civil Rights Fraud Initiative (the “Initiative”), which was announced on May 19, 2025 via Memorandum from Deputy Attorney General, Todd Blanche, and a related press release...more

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