Written by David B. Honig and Ritu Kaur Cooper. On February 3, 2015, the Fourth Circuit Court of Appeals ruled that disclosures to the public officials responsible for managing the subject of a False Claims Act lawsuit did not qualify as “public disclosures” for the purpose of the FCA’s public disclosure bar. US... Continue Reading →Tags: audit, Bank of Farmington, compliance, David B. Honig, False Claims Act, FCA, Graham County, original source, public disclosure, qui tam, Rita Kaur Cooper, self-disclosure, whistleblower
Yesterday, the D.C. Circuit issued a much-anticipated decision regarding whether or not internal compliance investigations were privileged. Two recent lower court decisions had ruled that such compliance investigations were not privileged because they were for business rather than legal purposes. The D.C. Circuit disagreed and found that such compliance investigations... Continue Reading →Tags: compliance, D.C. Circuit, discovery, internal investigation, privilege