News & Analysis as of

False Claims Act (FCA) Fraud Corporate Counsel

McDermott Will & Schulte

DOJ complaint underscores Trump administration’s use of the FCA to enforce US trade laws

A recent complaint – U.S. ex rel. Joyce v. Global Office Furniture, LLC, et al. – marks one of the Trump administration’s first publicly filed False Claims Act (FCA) enforcement actions focused on tariff evasion. In its July...more

Morrison & Foerster LLP

DOJ Deploys Specialized Criminal Unit to Target Tariff Evaders

The United States Department of Justice (DOJ) has deployed its Market Integrity and Major Frauds Unit to target tariff evasion, a clear sign of the escalation of trade enforcement. The Criminal Division’s specialized unit,...more

Clark Hill PLC

Key lessons on the False Claims Act for government contractors after Raytheon’s $8.4 million settlement

Clark Hill PLC on

Government contractors should be on high alert following the recent announcement that Raytheon Company, its parent RTX Corporation, and Nightwing Group, LLC, have agreed to pay $8.4 million to resolve allegations of violating...more

Mintz

Dodging Duties: The Ninth Circuit Affirms an Expansive Application of the False Claims Act Consistent with Trump Administration...

Mintz on

On June 23, 2025, the United States Court of Appeals for the Ninth Circuit affirmed a district court judgment in a case in which the jury found the defendant knowingly made false statements on customs forms to avoid paying...more

Seyfarth Shaw LLP

The False Claims Act Comes to Britain? Preparing for the ‘Failure to Prevent Fraud’ Offence

Seyfarth Shaw LLP on

In just a few months, the UK’s corporate criminal liability offence of Failure to Prevent Fraud (FTPF) comes into force. Modelled on the framework of the Failure to Prevent Bribery offence, FTPF imposes strict liability on...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

Foley Hoag LLP - White Collar Law &...

Are There Legitimate Ways to Achieve More Advantageous Tariff Classifications?

With recent increases in U.S. tariffs and the increasing complexity of determining applicable duties for different products, importers are looking for ways to reduce their tariff exposure. Since a product’s tariff treatment...more

Proskauer - Health Care Law Brief

First Circuit Clarifies FCA Liability Standard for AKS Violations, Deepening Circuit Split

The First Circuit has issued its long-anticipated opinion in United States v. Regeneron Pharmaceuticals, Inc., clarifying the standard for establishing False Claims Act (“FCA”) liability based on Anti-Kickback Statute (“AKS”)...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

Holland & Hart LLP on

On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Skadden, Arps, Slate, Meagher & Flom LLP

Contractors Settle Cyber Fraud Claims Alleging Ignored Security Measures

Two recent settlements under the False Claims Act (FCA): - Signal enhanced risk around cybersecurity for recipients of federal funds. - Underscore the need to assess compliance with cybersecurity requirements and...more

McGuireWoods LLP

DOJ and Aerojet Settle for $9 Million in Qui Tam Cybersecurity False Claims Act Case

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On July 8, 2022, the U.S. Department of Justice announced a $9 million settlement with federal government contractor Aerojet Rocketdyne, Inc. for alleged violations of the False Claims Act (FCA) in a case pending in the...more

Dorsey & Whitney LLP

More DOJ Double-Dipping PPP Fraud News

Dorsey & Whitney LLP on

The Department of Justice (“DOJ”) continues rolling out new settlement agreements related to COVID-19 fraud - highlighting the government’s and a common relator’s efforts to crack down on those alleged to have improperly...more

Carlton Fields

DOJ’s First Cyber-Fraud Settlement Places Emphasis on Cybersecurity Shortfalls

Carlton Fields on

Last year, the Department of Justice (DOJ) unveiled its Civil Cyber-Fraud Initiative, intended to ensure compliance, by leveraging the False Claims Act (FCA), with contractual cybersecurity requirements applicable to...more

McGuireWoods LLP

DOJ Settles First False Claims Act Enforcement Action Since Launch of Civil Cyber-Fraud Initiative

McGuireWoods LLP on

On March 8, 2022, the U.S. Department of Justice (DOJ) announced a $930,000 settlement with Comprehensive Health Services, LLC (CHS) for alleged violations of the False Claims Act (FCA). This settlement marks DOJ’s first...more

Foley Hoag LLP - White Collar Law &...

False Claims Act Enforcement in 2022: What To Expect In The Year Ahead

This is the seventh post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed SEC Enforcement in 2022: A Look Ahead. Up next: ESG and the SEC: What’s Next on the...more

ArentFox Schiff

DOJ's New Civil Cyber-Fraud Initiative and How a Pending Case Could Test Its Efficacy

ArentFox Schiff on

The Department of Justice recently announced a new initiative that aims to hold government contractors accountable when they fail to meet required cybersecurity standards. In announcing the “Civil Cyber-Fraud Initiative” in...more

Holland & Knight LLP

False Claims Act Meets Cybersecurity: DOJ's New Civil Cyber-Fraud Unit

Holland & Knight LLP on

Earlier this week, the U.S. Department of Justice (DOJ) announced the launch of its new Civil Cyber-Fraud Initiative — an effort designed to harness the department's knowledge in civil fraud enforcement, government...more

BakerHostetler

Important Lessons from the DOJ's First Civil Action for CARES Act Loan Fraud

BakerHostetler on

On January 12, 2021, the Department of Justice (the “DOJ”) settled its first civil action for alleged fraud against the Paycheck Protection Program (the “PPP”) – the primary lending program under the Coronavirus Aid, Relief,...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s Civil Division Outlines Enforcement Priorities and Focus on COVID-19 Related Fraud

- The Department of Justice (DOJ) will focus its civil enforcement activity on fraud and other illegal actions relating to COVID-19, including with respect to CARES Act stimulus programs and consumer products marketed for use...more

Foley Hoag LLP - White Collar Law &...

DOJ Brings First Payroll Protection Program-Related Criminal Case

On Tuesday, May 5, the Department of Justice (DOJ) filed charges in the federal District Court of Rhode Island against David A. Staveley and David Butziger for conspiracy to make a false statement and conspiracy to commit...more

Bass, Berry & Sims PLC

Relax, Sixth Circuit Opinion Indicates Rule 9(b) Pleading Requirement Still Has Bite

Bass, Berry & Sims PLC on

A recent Sixth Circuit opinion in U.S. ex rel. Hirt v. Walgreen Co. should come as welcome news for FCA defendants concerned about the implications of the Sixth Circuit’s application last year, for the first time, of a...more

Proskauer - Whistleblower Defense

Seventh Circuit Issues Ruling Interpreting False Claim Act Whistleblower Amendments

The Seventh Circuit recently issued a decision interpreting the anti-retaliation provisions of the False Claims Act (FCA). The decision provides important clarifications about how courts may interpret recent amendments to...more

Faegre Drinker Biddle & Reath LLP

7th Cir. Demands Objective Standards in Whistleblower Complaint

On September 1 the Seventh Circuit affirmed dismissal of three of a whistleblower’s four fraud allegations against a mental health clinic, ruling that the allegations were based on the whistleblower’s subjective judgment...more

Saul Ewing LLP

Seventh Circuit Clarifies “Heightened” Pleading Standard for Fraud Claims under the False Claims Act

Saul Ewing LLP on

A recent decision of the United States Court of Appeals for the Seventh Circuit addressed the standard that courts should use to decide whether a whistleblower plaintiff has adequately pleaded that a defendant committed fraud...more

Dorsey & Whitney LLP

District Court Rejects “Worthless Services” FCA Claim, Interprets First-to File Bar and Res Judicata in FCA Context

Dorsey & Whitney LLP on

Earlier this month, the U.S. District Court for the Eastern District of Virginia dismissed a 2-count False Claims Act (FCA) complaint against Unisys Corporation. United States ex rel. Soodavar v. Unisys Corp., 2016 WL 1367163...more

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