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The Global Investigations Review Guide to Compliance

Client Alert | 1 min read | 08.12.24

As the primary civil enforcement statute for investigating and remedying fraud in connection with United States government programs, the False Claims Act (FCA) has resulted in more than $75 billion in recoveries of government funds since 1986. The FCA imposes liability on any person or entity that knowingly submits false claims or certifications to the government or improperly retains money owed to the U.S. government.

In this first-ever chapter on the False Claims Act published by the Global Investigations Review Guide to Compliance, Crowell attorneys provide an informed practical explanation of the requirements of the FCA for both U.S. and international companies and institutions. The chapter describes issues that arise in the investigation and litigation process, as well as common theories of liability in two industries that continue to be targets for FCA actions: government contracts and healthcare.

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Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....