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False Claims Act (FCA) Whistleblowers Corporate Counsel

Husch Blackwell LLP

The Risks of Trade-Related FCA Enforcement

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In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough,...more

Troutman Pepper Locke

With New Tariffs, Recent Settlements May Foreshadow Future DOJ Enforcement

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The Trump administration’s implementation of tariffs on August 7, 2025, will have profound implications for companies engaged in international supply chains. These tariffs are poised to increase business costs, affecting a...more

White & Case LLP

DOJ Secures First of Its Kind Cybersecurity False Claims Act Settlement

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On July 30, 2025, the U.S. Department of Justice (DOJ) announced that biotechnology company Illumina Inc. agreed to pay $9.8 million plus interest to resolve allegations of misrepresenting compliance with federal...more

Blank Rome LLP

The Frontline is Everywhere: What General Counsel Need to Know About the Department of Justice’s Strategic Pivot Toward Customs...

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Introduction - The U.S. Department of Justice (“DOJ”) has announced a significant realignment of resources that will fundamentally reshape criminal enforcement of international trade rules. By combining senior prosecutors...more

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

Clark Hill PLC

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

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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...

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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

DLA Piper

Ninth Circuit Holds Private Parties Can Bring Claims Against Importers Under the False Claims Act for Antidumping Duty Evasion

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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

Seyfarth Shaw LLP

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

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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

Morrison & Foerster LLP

True Facts About False Claims: MoFo's FCA Newsletter - April 2025

Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter,...more

Bass, Berry & Sims PLC

Key Takeaways from DOJ’s Continued Cybersecurity Enforcement

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On March 25, the U.S. Department of Justice (DOJ) announced a $4.6 million settlement with MORSECORP, Inc. (MORSE) over its alleged failures to satisfy cybersecurity requirements for federal defense contractors....more

Mintz - Privacy & Cybersecurity Viewpoints

DOJ: ‘False Claims Act + Cybersecurity’ Is Here To Stay

Amid ongoing policy shifts in Washington, the federal government’s interest in pursuing civil cyber-fraud cases appears to be here to stay. In October 2021, the Department of Justice (DOJ) initiated its Civil Cyber-Fraud...more

Bass, Berry & Sims PLC

DOJ Settlement Highlights Customs, FCA Risks for Importers

On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The...more

Blank Rome LLP

False Claims Act Liability Based on a DEI Program? Let’s Think It Through

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One of the more attention-grabbing aspects of Executive Order (“EO”) 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” is the specter of False Claims Act (“FCA”) liability for federal contractors...more

Womble Bond Dickinson

For Whom the Bell Tolls? The Impact of Wisconsin Bell v. United States ex rel. Todd Heath and United States v. Regeneron...

Womble Bond Dickinson on

The Supreme Court’s decision in Wisconsin Bell v. United States ex rel. Todd Heath clarifies what constitutes a “claim” under the federal False Claims Act (FCA). ...more

King & Spalding

Recent Decisions and DOJ Policy Announcements Signal Key Changes to FCA Enforcement and Litigation Environment

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Recent legal and political False Claims Act (“FCA”) developments signal a potentially turbulent time for the defense of investigations and lawsuits brought under the FCA...more

Alston & Bird

How DOJ Could Pursue Civil and Criminal Enforcement Actions Against Private-Sector DEI/DEIA Programs

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Our White Collar, Government & Internal Investigations and Labor & Employment Groups examine how the Department of Justice (DOJ) could use civil and criminal actions to enforce diversity, equity, and inclusion (DEI) Executive...more

Arnall Golden Gregory LLP

Federal Government Contractors May No Longer Have 90 Days to Comply With Trump Administration’s DEI Executive Order

GSA FAR Class Deviations - Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” issued on January 21, 2025, caused immediate confusion for federal government contractors since their...more

Troutman Pepper Locke

Trump Pauses FCPA Enforcement: Implications for Corporate Compliance Strategies

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On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more

Morrison & Foerster LLP - Government...

President Trump’s DEI Certification for Federal Contractors Creates Significant FCA Risk

On January 21, 2025, President Trump signed an executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (the “Order”), rescinding affirmative action under Executive Order 11246 and other...more

Proskauer Rose LLP

Top 10 Whistleblowing and Retaliation Events of 2024

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Following our annual tradition — which started over a decade ago — we are analyzing the year's 10 most significant whistleblower and retaliation events. As you'll see, in 2024, actions taken by a range of courts and...more

DLA Piper

Federal Judge Rules Whistleblower Provision of the False Claims Act is Unconstitutional

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In an eye-opening decision, a judge in the Middle District of Florida held that the unique whistleblower, or “qui tam,” provision of the federal False Claims Act (FCA) violates the Appointments Clause of Article II of the...more

Holland & Hart LLP

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

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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

Cozen O'Connor

Are You Secure? DOJ’s Cyber-Fraud Initiative and Heightened FCA Enforcement

Cozen O'Connor on

False Claims Act (FCA) enforcement has routinely targeted false information supplied to Medicare and Medicaid. A new trend in false-reporting cases is emerging under the FCA’s broad authority — cybersecurity enforcement....more

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