False Claims Act

In my recent interview with Federal News Network, I discussed the Department of Justice’s increasing use of the False Claims Act (FCA) to pursue allegations related to employment practices at federal contractors and what recent enforcement activity means for organizations that receive federal contract and grant funding. We explored recent settlements involving major government contractors and the broader implications for compliance and risk management.

Continue Reading False Claims Act Enforcement and Employment Practices: What Federal Contractors Need to Know

On September 9, the U.S. Department of the Treasury announced that the Financial Crimes Enforcement Network (FinCEN) had identified approximately $17.5 billion in suspicious financial activity potentially connected to healthcare fraud. Part of the Treasury Department, FinCEN has primary responsibility for administering and enforcing U.S. anti-money laundering laws such as the Bank Secrecy Act (BSA).
Continue Reading FinCEN Identifies $17.5 Billion in Suspected Healthcare Fraud, Reinforces Prior Warning to Financial Institutions

On September 17, Florida Attorney General James Uthmeier announced that Starbucks agreed to pay $1 million and undertake several commitments to resolve a lawsuit alleging that Starbucks engaged in employment practices that violated the Florida Civil Rights Act through race- and sex-based goals, quotas, and preferences. The settlement comes amid increased federal enforcement involving similar practices, including recent FCA settlements involving federal contractors Accenture, Deloitte, and IBM.… Continue Reading Starbucks Settlement Adds to Growing Scrutiny of Corporate DEI Programs

The Department of Justice (DOJ) continues to use the False Claims Act (FCA) to pursue government contractors for alleged failures to comply with contractual cybersecurity requirements. On September 1, DOJ announced that Honeywell Aerospace Inc. agreed to pay $2,042,518 to resolve allegations that a Honeywell business unit failed to comply with required cybersecurity controls under a Department of War (DoW) contract. The settlement is the latest example of DOJ treating cybersecurity compliance as more than an information technology issue. For federal contractors, deficiencies in required cybersecurity controls can also create significant FCA exposure.…

Continue Reading DOJ’s $2 Million Honeywell Settlement Under the Civil Cyber-Fraud Initiative: What Compliance Failures Mean for Defense Contractors

On September 14, the U.S. Department of Justice (DOJ) announced that Accenture Federal Services (AFS), Accenture plc, and Accenture LLP (collectively, Accenture or AFS) agreed to pay $25 million to resolve allegations that AFS violated the False Claims Act (FCA) by falsely certifying compliance with anti-discrimination requirements in its federal contracts while engaging in employment practices that allegedly discriminated based on race or sex. Of the $25 million settlement, approximately $11.6 million constitutes restitution, and Accenture denies that it engaged in the alleged conduct.
Continue Reading DOJ Continues DEI False Claims Act Enforcement with $25 Million Accenture Settlement

The U.S. Department of Justice (DOJ) announced on August 25 that Deloitte has agreed to pay $21.5 million to resolve allegations that certain diversity, equity, and inclusion (DEI) practices discriminated against employees and applicants based on race or sex and caused the company to submit false claims for payment under federal contracts. The settlement is the latest enforcement action under DOJ’s Civil Rights Fraud Initiative and follows an April settlement in which IBM agreed to pay approximately $17 million to resolve similar allegations.
Continue Reading Deloitte DEI Settlement Highlights False Claims Act Risk at Both Federal and State Levels

The U.S. Small Business Administration (SBA) has finalized a significant change to how small businesses establish social disadvantage for purposes of the 8(a) Business Development Program. Effective September 10, 2026, SBA will eliminate the longstanding regulatory presumption that members of certain racial and ethnic groups are socially disadvantaged and replace it with a single standard available to applicants regardless of race. The rule also eliminates the existing narrative-based test for establishing individual social disadvantage, which SBA has applied to all individually owned applicants since the Ultima decision.
Continue Reading SBA Finalizes New Social Disadvantage Standard for 8(a) Program

As procurement fraud enforcement continues to be a priority for the Department of Justice and other federal agencies, we take a look back at significant 2025 enforcement developments affecting government contractors, grant recipients and participants in federal programs in our 2025 Procurement Fraud Review.

Continue Reading Procurement Fraud Enforcement Trends Continue Into 2026

On April 17, the Federal Acquisition Regulatory (FAR) Council issued guidance implementing Executive Order (EO or Order) 14398, Addressing DEI Discrimination by Federal Contractors, less than 30 days after the Order was signed and well ahead of the 60-day deadline the Order gave the Council to act. Because the Order required agencies to begin implementation within 30 days, the FAR Council likely took quick action to ensure a uniform government-wide approach to implementation of this requirement.

Continue Reading FAR Council Moves Quickly on DEI Executive Order, Which Has Already Been Challenged in District Court

At the end of March, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory urging financial institutions to heighten scrutiny of transactions potentially tied to healthcare fraud schemes targeting Medicare, Medicaid, and other federal and state healthcare benefit programs. The Advisory is accompanied by this press release.

Continue Reading FinCEN Advisory Warns Financial Institutions of Healthcare Fraud Targeting Medicare and Medicaid