On September 1, 2026, the Eleventh Circuit issued its long-anticipated decision in United States v. Florida Medical Associates, LLC, – F.4th –, 2026 WL 2581886 (11th Cir. Sept. 1, 2026) (the “Zafirov appeal”) overturning the district court and holding that the qui tam provisions of the False Claims Act (“FCA”) do not violate the Appointments Clause of Article II of the United States Constitution because relators are not officers of the United States that occupy “continuing positions.” The Eleventh Circuit did not reach other arguments made by the parties and remanded the case to the District Court for the Middle District of Florida to address two other constitutional arguments challenging the FCA’s qui tam provisions based on Article II’s Vesting and Take Care Clauses.
Continue Reading Next Stop, Supreme Court? Eleventh Circuit Upholds the Constitutionality of the FCA’s Qui Tam ProvisionsFalse Claims Act
DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement




On Tuesday, August 25, 2026, the U.S. Department of Justice (DOJ) announced that Deloitte LLP and several of its subsidiaries agreed to pay, collectively, $21.5 million to resolve allegations that Deloitte violated the False Claims Act (FCA) by failing to comply with new anti-discrimination requirements incorporated into its federal contracts, by discriminating against employees and applicants on the basis of race and sex, and by allocating and seeking reimbursement for costs related to those practices under its federal government contracts. This resolution is the second of its kind under DOJ’s recently launched Civil Rights Fraud Initiative, following a similar settlement by IBM in April 2026.
Continue Reading DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA SettlementRecent Deluge of Paycheck Protection Program False Claims Act Settlements




United States Attorneys’ Offices recently announced a number of False Claims Act (FCA) settlements arising out of the Paycheck Protection Program (PPP). These settlements reveal several trends that PPP loan recipients should be aware of.
Continue Reading Recent Deluge of Paycheck Protection Program False Claims Act SettlementsThe Top FCA Developments of 2024





FY 2024 saw continued growth in False Claims Act enforcement, with a record year for new qui tam and government-initiated actions, and the highest total recovery in three years. Enforcement of pandemic-related fraud and cybersecurity noncompliance increased, and health care, procurement, and small business fraud violations were again priority areas. A groundbreaking opinion from the…
Fastest 5 Minutes

Cyber, Semiconductors, AI, False Claims Act
This week’s episode covers cybersecurity updates, a proposed rule regarding prohibition on semiconductors produced by certain Chinese manufacturers, DOL guidance entitled “Artificial Intelligence and Equal Employment Opportunity for Federal Contractors,” and two settlements under the civil False Claims Act, and is hosted by Peter Eyre and Yuan Zhou. Crowell…
DOJ Offers Cash “Carrot” to Whistleblowers; Foreshadows “Stick” of More Corporate Enforcement



On March 7, 2024, Deputy Attorney General (DAG) Lisa Monaco delivered remarks at the American Bar Association’s 39th National Institute on White Collar Crime announcing a new Department of Justice (DOJ) pilot program that incentivizes whistleblowers to report corporate misconduct by offering monetary rewards. Likening the program to “the days of ‘Wanted’ posters across the Old West,” DAG Monaco explained that individuals who help DOJ discover otherwise unknown, “significant” corporate or financial crime could receive a portion of the resulting forfeiture. This program will encourage whistleblowers to report a broad range of criminal activity by bridging the divide between DOJ’s priorities and other whistleblower mechanisms such as the False Claims Act’s qui tam provision (which is only available for fraud against the government), and programs at the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), and other federal agencies (which only cover misconduct within their respective jurisdictions). By placing a bounty on corporate actors, this DOJ pilot program—which will be developed by the Department’s Money Laundering and Asset Recovery Section (MLARS)—underscores the need for companies to take stock of their compliance programs and enhance their internal reporting infrastructure.
Continue Reading DOJ Offers Cash “Carrot” to Whistleblowers; Foreshadows “Stick” of More Corporate EnforcementCounterclaims Against Compliance-Officer-Turned-Relator Survive Motion to Dismiss


A recent decision in a non-intervened qui tam suit in the Northern District of Georgia provides an example of a defendant threading the needle to avoid dismissal of its counterclaims despite those counterclaims arguably implicating the conduct that the relator alleged violated the False Claims Act (FCA). It also stands as a rare instance where a company’s counterclaims against an FCA relator have survived early court scrutiny and, as such, provides FCA defendants with a potential strategy to combat opportunistic relators.
Continue Reading Counterclaims Against Compliance-Officer-Turned-Relator Survive Motion to DismissLet’s Talk FCA


Criminal Investigations and the False Claims Act
In this episode, Steve Byers, Jason Crawford, and Agustin Orozco discuss the intersection between False Claims Act investigations and parallel criminal proceedings. “Let’s Talk FCA” is Crowell & Moring’s podcast covering the latest developments with the False Claims Act.
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Let’s Talk FCA


Cost Accounting and the False Claims Act
In this episode, Jason Crawford, Agustin Orozco, and Erin Rankin look back at one of the more noteworthy settlements of 2023—the $377M settlement by Booz Allen Hamilton to resolve allegations arising out of the company’s purported non-compliance with Cost Accounting Standards. “Let’s Talk FCA” is Crowell & Moring’s…
Fastest 5 Minutes: Claims and False Claims Act

This week’s episode covers a Federal Circuit decision about jurisdiction under the Contract Disputes Act, a claim for additional costs relating to COVID related delays, and a False Claims Act settlement touching on cybersecurity and self-disclosure, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast…