Qui Notes: Unlocking the False Claims Act
Welcome to Qui Notes, Arnold & Porter's forum for all things False Claims Act (FCA). Here, you will find insightful commentary and news on FCA recoveries as they happen. Our interactive "recoveries map" and "statistics" pages show where the action is, both geographically and by industry. Basic concepts are covered in our glossary, but use tags and the search tool to find points of particular interest. Whatever your issue, our FCA experts will keep a steady stream of posts coming so you are never out-of-date. The FCA is a potential trap for anyone doing business with the government — we hope Qui Notes will help you unlock it. Thanks for visiting.
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April 4, 2025
DOJ’s Civil-Cyber Fraud Initiative Strikes Again: DOD Contractor Settles Allegations Related to Implementation of NIST SP 800-171
The Department of Justice has inked its ninth cyber False Claims Act settlement under its civil cyber-fraud initiative that was announced in 2021.
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September 23, 2024
8(a) Graduate Gets Demerit: Eleventh Circuit Holds 8(a) Program Graduate Subject to FCA Liability Following Change in Control
Earlier this summer, the Eleventh Circuit held that graduates of the Minority Small Business and Capital Ownership Development Program are subject to certain program requirements as long as they continue to perform existing contracts, and that violation of those requirements can lead to False Claims Act liability under a fraudulent inducement theory.
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May 21, 2024
Seventh Circuit Weighs in on AKS/FCA Causation Standard Debate
Earlier this month, the Seventh Circuit issued an opinion addressing a few issues of note for our Qui Notes readers, including the circuit split on the causation standard for a False Claims Act (FCA) claim based on an alleged kickback, as well as the Eighth Amendment’s application to FCA monetary judgments.
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March 21, 2024
DOJ’s 2023 False Claims Act Recoveries and Early Trends in 2024
In the latest episode of Bona Fide Needs, Pub K Managing Editor Bill Olver spoke with Arnold & Porter False Claims Act Investigations & Defense attorneys Tirzah Lollar and Christian Sheehan for a discussion of DOJ’s FY23 False Claims Act (FCA) financial recoveries and enforcement trends for 2024.
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