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DOJ Reports $3.7B Haul in FY 2017 FCA Recoveries

Client Alert | 1 min read | 12.26.17

On December 21, 2017, the Department of Justice reported that it recovered more than $3.7 billion in settlements and judgments from civil False Claims Act (FCA) cases in Fiscal Year 2017. The FY 2017 recovery is the fourth largest total in thirty years. At the industry level, DOJ reported $2.47B in recoveries from the health care sector, $220M from defense companies, and approximately $1B from the remaining industries such as banking, higher education, and energy.

The change in presidential administration appears to have had little effect on FCA activity. The number of new FCA actions in FY 2017 remained high with relators bringing 674 new qui tam matters and DOJ initiating 125 matters on its own. These numbers are consistent with the prior five years and suggests that FCA will remain an active area for investigations and litigation in 2018.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....