False Eligibility Application For Grant May Violate FCA
Client Alert | 1 min read | 11.09.05
In a ruling that could expand the exposure of grantees to False Claims Act liability, the Seventh Circuit in United States ex rel. Main v. Oakland City University (Oct. 20, 2005) held that a relator stated an FCA claim based upon a private university's allegedly false representation, made on a "phase one" application to establish institutional eligibility for federal financial aid, that it would comply with laws prohibiting payment of incentive fees to recruiters for enrolling students. Rejecting the argument that the "phase one" application does not by itself seek any payment, the court reasoned that a false "phase one" eligibility application could be actionable as a "false record or statement" under the FCA because it supports subsequent "phase two" requests for specific loans and grants.
Insights
Client Alert | 7 min read | 06.24.26
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.
Client Alert | 3 min read | 06.24.26
Client Alert | 4 min read | 06.23.26
EPA Hands Over AI Data Center Regulation to States and Communities to Develop Best Practices
Client Alert | 3 min read | 06.22.26
