False Claims Act Update for Government Contractors

June 6, 2024

On June 6, Perkins Coie Partners Alexander Canizares and Barak Cohen provided an overview of the False Claims Act (FCA) enforcement landscape in 2024 with a focus on developments relevant to commercial contractors.

Drawing on their experience handling FCA investigations and litigation as well as mandatory disclosures, Alex and Barak addressed DOJ’s procurement fraud enforcement priorities, including its Civil Cyber-Fraud Initiative focusing on using the FCA to redress non-compliance involving cybersecurity and the implications of FCA enforcement for contractors facing new and emerging programs such as DoD’s cybersecurity assessment initiative.

In addition, the presentation covered:

DOJ efforts to incentivize companies to self-disclose non-compliance as well as cooperate in DOJ investigations.

The latest developments related to DOJ’s use of the FCA to pursue fraud involving the Paycheck Protection Program (PPP) and pandemic-related loans.
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