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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.

Insights

Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....