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Similar State FCA Allegations Yield Mixed Results

Client Alert | 1 min read | 03.03.05

In two California Civil False Claims Act (FCA) cases recently decided by different districts of the California Court of Appeal, California ex rel. Harris v. PricewaterhouseCoopers LLP (Jan. 20, 2005) and California ex rel. Bowen v. Bank of America (Jan. 31, 2005), qui tam relators got mixed results on their novel “reverse false claims”allegations that the defendants failed to report and turn over to the State unclaimed property as required by California law. In Harris, applying case law under the federal FCA, the court upheld liability against an escrow title company and reversed summary judgment in favor of its accountants; but in Bowen, the Court, also applying federal case law, upheld the dismissal of the consolidated complaint against several banks on the ground that the plaintiffs had failed to allege facts that would make the subject property “certain and liquidated,” such that no reverse false claim could arise from the failure to report and turn over the property.

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Client Alert | 3 min read | 03.12.26

DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy

On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”...