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COVID-19 Relief Enforcement Actions Highlight Ongoing Risk

The Department of Justice (DOJ) continues to demonstrate its sustained interest in COVID-19 relief fraud as an enforcement priority and we can expect to see persistent enforcement in this area....more

False Claims Act Fundamentals: How to Respond to a Civil Investigative Demand

A civil investigative demand (CID) is a tool, like a subpoena, that the government uses to obtain documents and information to investigate potential violations of the False Claims Act. The False Claims Act expressly...more

Mixed Messages: DOJ Releases New FCA Cooperation Guidelines, while Study Questions Whether Cooperation Actually Garners Credit

The U.S. Department of Justice (DOJ) routinely encourages the subjects of False Claims Act (FCA) enforcement actions to make voluntary disclosures and fully cooperate with the government on the premise that cooperation leads...more

“Significant Abuses of the Statutory Scheme:” District Court Criticizes Practice of Regular Extensions of the FCA Seal Period

The U.S. District Court for the Eastern District of Pennsylvania recently refused to extend the period during which a False Claims Act (FCA) action remains under seal while the government investigates and decides whether to...more

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