The 11th Circuit has vacated a 2024 decision from the Middle District of Florida and held that the qui tam provisions of the False Claims Act do not violate the Appointments Clause of the United States Constitution. In United States ex rel. Zafirov v. Florida Medical Associates, LLC, the court concluded that FCA relators
When conducting investigations or determining whether to bring charges, the Department of Justice (DOJ) evaluates whether a company’s AI governance prevents deliberate or reckless misuse that could violate criminal law. The Securities and Exchange Commission (SEC) evaluates whether a company’s public statements about its AI capabilities are accurate and not misleading to investors. These are
The autism therapy industry is a growing target for government enforcement. As I discussed recently in Emerging Target: Federal Enforcement Comes to the Autism Therapy Industry, Applied Behavior Analysis (ABA) therapy — currently the dominant type of autism therapy — has all the markers for healthcare fraud enforcement: explosive reimbursement growth, low barriers to
Trade fraud takes center stage and continues to expand as a priority for the Department of Justice (DOJ).
On July 14, 2026, the DOJ announced its plans to expand trade fraud enforcement by creating the Global Trade & Commerce Enforcement Section (GTCES) within the DOJ’s newly formed National Fraud Enforcement Division.
Notably, this new section
We previously wrote about the U.S. Securities and Exchange Commission’s (SEC) May 2026 withdrawal of its longstanding no-deny policy, under which a settling party generally could not deny the SEC’s allegations. At that time, we noted that a company settling with the SEC could now issue a statement disagreeing with the agency’s allegations, asserting it
Two recent settlements reached between federal antitrust authorities and antitrust defendants highlight that the federal government is open to settlements in which the defendants agree to curb allegedly anticompetitive conduct. The government publicly tallies the resolution as a win, and companies get out of tricky situations by following through on or expanding compliance initiatives already
China is increasingly on the minds of state legislators and regulators. Across the country, state legislatures and attorneys general have launched a growing wave of laws, enforcement units, and investigations targeting Chinese influence in American commerce, real estate, technology, and healthcare. The result is a rapidly expanding patchwork of state-level obligations that increasingly complements, and
While traditional government enforcement areas, such as healthcare, dominate headlines, one emerging enforcement priority continues to grow, albeit with less fanfare: compliance with cybersecurity requirements in government contracts. The government announced its most recent settlement last month, signaling that these enforcement actions continue to proliferate.
Cybersecurity enforcement is here to stay.
On June 29, 2026, the Supreme Court issued its long-awaited decision in Trump v. Slaughter. On its face, the case asked a simple question: Did President Trump act lawfully when, shortly after taking office in 2025, he fired the two Democratic members of the Federal Trade Commission? Much more was on the line, however
On June 23, 2026, the Department of Justice (DOJ) announced the results of the 2026 National Health Care Fraud Takedown. The so-called “takedowns” have become an annual event, and this year’s involved the largest number of defendants in Takedown history. For healthcare providers and organizations, the takeaway is clear: Enforcement is nationally coordinated, increasingly data-driven