On April 10, 2026, the Department of Justice (“DOJ”) announced a $17 million civil False Claims Act (“FCA”) settlement with IBM Corporation. This is the first FCA settlement reached under
Continue Reading First DEI Settlement Under the Civil Rights Fraud Initiative Targets Conduct Pre-Dating the Current AdministrationFCA 101: Materiality
This is the fourth blog in a series on the False Claims Act (FCA), 31 USC §§ 3729, et seq., which targets any person that knowingly submits false claims for
Continue Reading FCA 101: MaterialityThe Civilian Board of Contract Appeals Issues New Rules of Procedure for Its Adjudicatory Role in the Administrative False Claims Act
On January 28, 2026, the United States Civilian Board of Contract Appeals (CBCA) issued final rulemaking to address its role in hearing and resolving disputes under the Administrative False Claims
Continue Reading The Civilian Board of Contract Appeals Issues New Rules of Procedure for Its Adjudicatory Role in the Administrative False Claims ActDOJ’s 2025 FCA Statistics – Contractors Check Your Cybersecurity Compliance and Cost or Pricing Data
The U.S. Department of Justice (DOJ) published its 2025 False Claims Act (FCA) statistics on Friday with a record-breaking $6.8 billion in judgments and settlements last fiscal year. This was
Continue Reading DOJ’s 2025 FCA Statistics – Contractors Check Your Cybersecurity Compliance and Cost or Pricing DataFinal CMMC Rule Effective Nov 10, 2025: What Federal Contractors Need to Know
On September 9, 2025, the Department of Defense (DOD) released its long-anticipated final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program. As discussed previously, this rule marks a
Continue Reading Final CMMC Rule Effective Nov 10, 2025: What Federal Contractors Need to KnowWhat Federal Contractors and Grant Recipients Should Know About DOJ’s Unlawful Discrimination Guidance
On July 29, 2025, US Attorney General Bondi issued a memorandum for all federal agencies titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination” (the Memo). The Memo follows
Continue Reading What Federal Contractors and Grant Recipients Should Know About DOJ’s Unlawful Discrimination GuidanceSupreme Court Broadly Interprets Wire Fraud Liability
On May 22, 2025, the Supreme Court held that a defendant could be convicted of federal wire fraud pursuant to 18 USC § 1343 even when the fraud did not
Continue Reading Supreme Court Broadly Interprets Wire Fraud Liability
DOJ Announces New Civil Rights Fraud Initiative Targeting DEI
Deputy Attorney General Todd Blanche issued a memo on May 19, 2025, announcing the DOJ’s establishment of the Civil Rights Fraud Initiative. The initiative will “utilize the False Claims Act
Continue Reading DOJ Announces New Civil Rights Fraud Initiative Targeting DEI
Executive Orders to Watch for Federal Contractors and Fund Recipients
President Trump signed a multitude of Executive Orders (EOs) during his first two weeks in office. EOs are directives from the President to federal agencies that do not require Congressional
Continue Reading Executive Orders to Watch for Federal Contractors and Fund RecipientsFCA Whistleblower Complaints Reach All Time High in 2024
The U.S. Department of Justice (DOJ) published its 2024 False Claims Act (FCA) statistics and press release this week touting $2.9 billion in judgments and settlements last fiscal year, slightly
Continue Reading FCA Whistleblower Complaints Reach All Time High in 2024