AI and the False Claims Act
False Claims Act Insights - The Mathematics of Nuclear FCA Verdicts
Episode 379 -- Update on False Claims Act and Customs Evasion Liability
Great Women in Compliance: The Compliance Influencer with Bettina Palazzo
Blowing the Whistle: What Employers Should Know About DEI & the False Claims Act
When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?
Enforcement Priorities of the Second Trump Administration: The False Claims Act
Episode 372 -- DOJ Applies False Claims Act to Tariff and Trade Violations
False Claims Act Insights - How Payment Suspensions Can Impact FCA Litigation
False Claims Act Insights - Trump DOJ Sharpens Its Focus on Healthcare Fraud
False Claims Act Insights - DOJ’s Reliance on FCA to Pursue Covid-Related Fraud
UPIC Audits
Criminal Health Care Fraud Enforcement: Projections for 2025 and Beyond – Diagnosing Health Care Video Podcast
False Claims Act Insights - Stranger Than Fiction? An FCA April Fools’ Day Episode
#WorkforceWednesday®: Federal Contractors Alert - DEI Restrictions Reinstated by Appeals Court - Employment Law This Week®
False Claims Act Insights - Emptying Our FCA Notebook: A Summary of Recent FCA-Related Developments
PilieroMazza Annual Review: What DOJ’s 2024 FCA Report Means for Government Contractors
False Claims Act Insights - Some FCA Whistles Are Louder Than Others
As part of the Trump administration’s broad repositioning of US international trade policy toward higher tariffs and enhanced customs enforcement, on 12 May 2025, the head of the Criminal Division of the Department of Justice...more
Escalating what has already been a strong focus on combating customs and trade fraud in President Donald Trump’s second administration, on July 10, 2025, the Department of Justice announced it would be devoting significant...more
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
The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more
As importers await outcomes from the Trump Administration's trade negotiations, a series of newly imposed tariffs continues to impact a broad spectrum of imported products and related supply chains. Businesses are currently...more
DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __...more
As the US administration has imposed and modified tariffs on key trading partners, the US Department of Justice has turned its focus to criminally prosecuting companies and individuals for tariff evasion....more
A recent Ninth Circuit decision underscores why importers should be worried that they will be hit with a large government bill under the False Claims Act (FCA) to pay for newly raised duties imposed on imported products. The...more
The Ninth Circuit’s recent decision in Island Industries Inc. v. Sigma Corporation, coupled with recent government pronouncements concerning trade enforcement, are likely to drive an increase in customs fraud FCA...more
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
Tariffs have been in the news almost daily. Not only have tariff rates changed repeatedly, but the deadlines around implementation are subject to change. Meanwhile, the list of new commodities that are subject to additional...more
The United States Court of Appeals for the Ninth Circuit has issued a significant ruling with potentially far-reaching consequences for companies that import merchandise, including but not limited to those subject to...more
The American trade landscape has transformed rapidly as the United States’ “America First” national-security platform reshapes international relations. New executive orders, proclamations, and memoranda issued under the...more
On May 12, 2025, the U.S. Department of Justice’s (DOJ) Criminal Division released a memorandum containing the Trump Administration’s new white collar enforcement priorities. Consistent with the Administration’s heightened...more
The increase in tariffs and export control actions by the Trump Administration has led to additional reporting and compliance obligations for companies that import and export goods. To ensure these new tariffs and rules are...more
Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s...more
What if your trade compliance misstep became tomorrow’s federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating...more
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
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
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
The United States has intervened and filed a superseding complaint in a False Claims Act case originally filed by a whistleblower in the Eastern District of California. The Government’s complaint alleges that an importer and...more
A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as...more
On May 12, 2025, head of the Department of Justice Criminal Division Matthew Galeotti delivered a speech in which he stated that the Department augmented its corporate whistleblower program to prioritize the following subject...more
As we discussed in this April 7 blog post, the US Department of Justice (DOJ) can pursue civil penalties for tariff evasion under the False Claims Act (FCA), including against companies that are aware of tariff evasion by...more