Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Christina Egan

Photo of Christina Egan Christina practices in the area of government, regulatory and criminal investigations. An experienced trial lawyer, she focuses her practice on representing companies and individuals with matters involving both criminal and civil investigations by the government as well as federal and state regulators.

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Schemes that Deprive a Person of “Potentially Valuable Economic Information” – Punishable Under the Federal Wire Fraud Statute?

By Christina Egan and McGuireWoods LLP on Fraud, Deception and False Claims
On Monday November 28, 2022, the U.S. Supreme Court heard oral arguments on Ciminelli v. United States. The Court will decide whether the “right-to-control” theory of fraud used by the Second Circuit is a valid basis for property fraud liability under the federal wire fraud statute. Courts and prosecutors have used the right-to-control theory to… Continue Reading

DOJ Title IX Investigation Leads to $1.6M Agreement with San Jose State University

By Christina Egan, Farnaz Farkish Thompson and Evan Tucker on Compliance
The Department of Justice’s Civil Rights Division, the U.S. Attorney’s Office for the Northern District of California, and San Jose State University (SJSU) settled the government’s Title IX investigation into a decade’s worth of sexual harassment allegations. The June 2020 allegations of “employee-on-student sexual harassment” and retaliation within SJSU’s athletics department prompted the government’s investigation.… Continue Reading

Income Share Agreements – Risks, Rewards, and Regulators

By Farnaz Farkish Thompson, Christina Egan and McGuireWoods LLP on Financial Institution Regulation
An Income Share Agreement (ISA) is a contract in which a lender gives a student money for education, and in return, the student promises to pay the ISA-provider a fixed percentage of the student’s income for a set amount of time after graduation. The student may repay more or less than the amount received, depending… Continue Reading

Analysis of the DOJ’s 2020 FCA Statistics and the Trends Therein

By Michael J. Podberesky, David Pivnick, Christina Egan and Jeremy Byrum on Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims, Government Contracts
The U.S. Department of Justice (DOJ) recently issued its annual press release summarizing fraud-related recoveries from False Claims Act (FCA) matters in the prior fiscal year. While the headline number for FY 2020 of $2.2 billion in settlements and judgments involving fraud and false claims against the government is down about $900 million from the… Continue Reading

DOJ Puts Collection of Civil Penalties on Hold in Response to COVID-19

By Christina Egan, David Pivnick and R. Andrew Austria on Compliance
In a pair of recent memoranda from the Executive Office for United States Attorneys (“EOUSA”) issued on March 31, 2020, and April 13, 2020, the United States Department of Justice (“DOJ”) has effectively halted enforcement actions and the collection of civil penalties.  Included in this temporary suspension is the collection of civil penalties incurred in… Continue Reading

Positive FCA Enforcement Trend for Defense Contractors: DOJ Reaffirms Commitment to Exercise Statutory Authority to Dismiss

By Edwin O. Childs, Christina Egan, Todd R. Steggerda and McGuireWoods LLP on Compliance
Following recent changes to Department of Justice policy regarding individual accountability in government investigations of corporate wrongdoing, DOJ has recently further demonstrated its willingness to consider a flexible approach in applying the False Claims Act. In a January 28, 2019 speech by Deputy Associate Attorney General Stephen Cox to the 2019 Advanced Forum on False Claims… Continue Reading

Healthcare Executive Indicted for Alleged Cover-Up

By Christina Egan and Government Investigations Group on Compliance, Enforcement and Prosecution Policy and Trends
A recent federal government indictment of a former executive for national hospital chain Health Management Associates (HMA) provides yet another example of the fact that a cover-up can lead to consequences as severe as the crime itself.  The indictment, which was unsealed November 26, charges the executive, who worked for HMA between 1994 and 2011,… Continue Reading

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