Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Brandi G. Howard

Photo of Brandi G. Howard Brandi’s practice focuses on representing corporate and individual clients in government investigations and complex commercial trial and appellate litigation. Brandi defends clients against allegations of violations of the False Claims Act, and participates in internal investigations involving healthcare fraud, antitrust issues, and anti-money laundering issues.

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California Signs New Bill Prohibiting CA-based Tech Companies from Disclosing Data for State Abortion Investigations

Enforcement and Prosecution Policy and Trends
Compliance with out of state investigative requests, like warrants, just got a little trickier for California companies. Under existing law, California technology and communications companies are required to produce specified user data in response to an out of state warrant as if that warrant was issued by a California court. But now there is one… Continue Reading

Twitter to Pay $150M for Violating 2011 FTC Order Regarding Misrepresentation of its Privacy and Security Practices

Enforcement and Prosecution Policy and Trends
On May 25, 2022, the Federal Trade Commission (FTC) announced that it, along with the Department of Justice, fined Twitter $150 million for violating a 2011 agreement the company had with the Commission. Under the 2011 FTC order, Twitter agreed that it would protect the integrity of nonpublic consumer information, including users’ phone numbers and… Continue Reading

CFPB’s New Interest in Examining Fintechs is Likely to Mean More Naming and Shaming by the Agency

Financial Institution Regulation
On April 25, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it will begin examining nonbank “covered persons” that it has determined pose risks to consumers. The CFPB has had this authority since its inception. The Dodd-Frank Act empowered the CFPB to examine this category of nonbanks, which might include fintech firms that are… Continue Reading

Analysis of DOJ’s 2021 FCA Statistics and the Trends Therein

Fraud, Deception and False Claims
Last week, the U.S. Department of Justice (DOJ or Department) announced that it recovered over $5.6 billion under the False Claims Act (FCA) in Fiscal Year 2021.[1] That is a massive headline haul that is second only to the roughly $6 billion recovered under the FCA in FY 2014, when there were $3.1 billion in… Continue Reading

U.S. Attorney’s Office Settles with Urgent Care Providers to Resolve False Claims Act Allegations Related to Credentialing Issues

Fraud, Deception and False Claims
On April 8, 2021, the U.S. Attorney’s Office for the District of South Carolina announced a $22.5 million settlement with a network of urgent care providers, Doctors Care, P.A. (Doctors Care), and its management company, UCI Medical Affiliates of South Carolina, Inc. (UCI), for alleged False Claims Act (FCA) violations.… Continue Reading

DOJ Announces Plan for Coordinated Civil Rights Response to COVID-19

Compliance
On April 2, 2021, Pamela S. Karlan, the Principal Deputy Assistant Attorney General for Civil Rights at the U.S. Department of Justice Civil Rights Division (DOJ), issued a public statement regarding the Division’s intent to lead a coordinated civil rights response to the Coronavirus (COVID-19) pandemic. The statement, which attached a resource guide, is intended… Continue Reading

U.S. Supreme Court Declines to Clarify False Claims Act Falsity Standard

Fraud, Deception and False Claims, Government Contracts
The U.S. Supreme Court recently declined to address a circuit split regarding the standard for establishing that a statement material to a claim for payment is false under the False Claims Act (FCA); specifically, whether the FCA requires pleading and proof of an “objectively false statement,” or whether liability can be based on allegedly false… Continue Reading

DOJ Accelerates Enforcement Efforts Against Cybercriminals Who Engage in Ransomware Attacks

Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
On successive days last week, the Department of Justice (DOJ) unveiled enforcement actions against international cybercriminal organizations that utilized ransomware to infect computer systems and then extort payment, often in the form of cryptocurrency, from victims worldwide.  First, the Criminal Division’s Computer Crime and Intellectual Property Section and the U.S. Attorney’s Office for the Middle… Continue Reading

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