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Erin Sullivan has years of experience representing corporate and individual clients involved in investigations, prosecutions, and civil enforcement actions by federal and state government entities. She routinely conducts internal investigations, whether prompted by an existing government investigation or initiated internally for business or compliance reasons.

The Eighth Circuit split with the Third Circuit over the appropriate causation standard in False Claims Act (FCA) cases involving alleged violations of the Anti-Kickback Statute (AKS), holding that the 2010 amendments to the AKS created a “but-for causal requirement” (United States ex rel. Cairns v. D.S. Medical, LLC).

In 2010, Congress amended