1. Home
  2. |Insights
  3. |The Top FCA Developments Of 2018

The Top FCA Developments Of 2018

Client Alert | less than 1 min read | 02.04.19

From the government’s renewed use of its dismissal authority to changes to the policy on corporate cooperation credit, the second year of False Claims Act (FCA) enforcement under the Trump administration was defined by several announcements concerning how the Department of Justice (DOJ) will pursue cases under the FCA. These policy reforms are among the many FCA developments highlighted by C&M attorneys in a "Feature Comment" published in The Government Contractor, which considers key issues such as small business fraud, materiality post-Escobar, trade and domestic preferences, and the Supreme Court’s review of a circuit split concerning the statute of limitations.

Insights

Client Alert | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....