We just released Episode 36 of the False Claims Act Insights podcast with Husch Blackwell partner Lorinda Holloway where we discussed how the acts of employees can be held against organizations for False Claims Act purposes. Vicarious liability can be an odd fit with the False Claims Act, and courts take a few different approaches
We just released Episode 35 of the False Claims Act Insights podcast where I discussed the growing amount of state-level False Claims Act enforcement with Husch Blackwell partners Rebecca Furdek and Todd Gee.
State FCA enforcement varies widely from state to state, but an increasing number of states are using FCA to combat different
In white-collar criminal cases, forfeiture is one of the most consequential sentencing components, yet it remains overlooked and misunderstood by practitioners. The U.S. Court of Appeals, Second Circuit’s recent decision in United States v. Ng Chong Hwa demonstrates why a thorough understanding of forfeiture is essential.
2025 has been a landmark year for False Claims Act (FCA) enforcement, marked by record-breaking settlements, evolving legal theories, and a broadening scope of government priorities. The FCA remains one of the federal government’s most potent tools for combating fraud, with billions recovered annually and an ever-expanding reach into new sectors and compliance areas. This roundup synthesizes the year’s most significant developments—drawing on recent case law and shifting enforcement priorities—and provides actionable insights for businesses navigating the FCA landscape.
2025 marked another notable year in State Attorneys General (AG) enforcement, with both a sharp uptick in multistate AG actions filed against the federal government and significant actions targeting the private sector across industries. We will highlight two issue areas here—antitrust and consumer protection—and describe the escalating friction between State AGs and the federal government as well as distill this year’s trends into actionable takeaways for businesses as we enter 2026.
We just released Episode 34 of the False Claims Act Insights podcast where I had a great conversation with Jody Rudman about the new Zafirov oral argument into whether qui tams are unconstitutional. We discuss how the role of whistleblowers in the False Claims Act is unique among government whistleblower rewards programs, in that False
On May 12, 2025, the Department of Justice (DOJ) announced revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). As stated by Matthew Galeotti, head of the DOJ’s Criminal Division, the purpose of the revised CEP is to incentivize companies to “come forward, come clean, reform, and cooperate with the government in efficient investigations
In August 2025, the U.S. Department of Justice (DOJ) declined to prosecute an insurance company for alleged violations of the Foreign Corrupt Practices Act (FCPA), marking the first action of its kind since the DOJ paused FCPA prosecutions earlier this year. DOJ’s decision came in response to the company’s voluntary self-disclosure. Importantly, this decision allows the company to avoid criminal charges in connection with bribes allegedly paid by employees of its foreign subsidiary for customer referrals for products. As part of the resolution with DOJ, the company will disgorge approximately $4.7 million in profits that are tied to the misconduct.
On September 23, we launched our Government Enforcement, Compliance & Investigations webinar series, a new monthly webinar program covering Department of Justice criminal enforcement, False Claims Act, antitrust, and state attorney general topics.
In the kickoff webinar, Jody Rudman, Wendy Arends, Matt Diehr, and I joined in a broad discussion on government enforcement. Jody and I
On August 29, 2025, the Department of Justice (DOJ) launched a new Trade Fraud Task Force, which will leverage resources from DOJ’s Civil and Criminal Divisions as well as the Department of Homeland Security (DHS) to enforce tariff and duties evasion, smuggling, and other import violations. The initiative furthers the Trump Administration’s “America First Trade Policy” announced on Inauguration Day and in Executive Order 14243, which promotes information-sharing between agencies to support the administration’s overall goals of combating waste, fraud, and abuse.