False Claims Act Guide

2019 and the road ahead

Executive summary

Executive summary

We are pleased to bring you Hogan Lovells 2020 False Claims Act (FCA) Guide, in which we provide our current analyses of trends in FCA enforcement. By looking back at the events of 2019 and looking forward to what lies ahead, we aim to help you navigate the frequently turbulent waters of FCA enforcement.

The Department of Justice (DOJ) recovered just over $3 billion through settlements and judgments in civil cases involving fraud and false claims against the government during fiscal year 2019, which ended September 30, 2019. This figure is up from $2.8 billion in 2018 and down from $3.5 billion in 2017.

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Quote

“It’s been a few years of mixed messages. On the one hand, we’ve had the Brand and Granston memos discouraging aggressive False Claims Act enforcement. But on the other hand, there have been instances where DOJ seems to be expanding the playing field.”

Michele W. Sartori

Michele W. Sartori

Partner

2019 and the road ahead

2019 and the road ahead

The False Claims Act at the Supreme Court

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AseraCare decision

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Creditworthy: The FCA and DOJ's cooperation credit policy

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Riding the relator roller coaster: DOJ's efforts to curtail declined qui tam litigation

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Lessons from Polansky : the role of sub-regulatory guidance in FCA litigation

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Cybersecurity and the False Claims Act: A new frontier for contractor liability?

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FCA enforcement in the financial services sector

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False Claims Act & California Insurance Fraud Prevention Act update

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Looking ahead

A busy year for Hong Kong’s enforcement authorities

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