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Federal Employees as Relators OK'ed

Client Alert | less than 1 min read | 08.07.12

In Little v. Shell Exploration & Production Co., the Fifth Circuit joined the Tenth and Eleventh Circuits in holding that federal employees, like private citizens, can bring whistleblower suits under the False Claims Act--even when those employees are auditors whose job is to investigate fraud. The Sixth and Ninth Circuits have also implicitly held that federal employees are not barred from acting as relators, while the First Circuit has held that at least some federal employees may not be qui tam plaintiffs.

Insights

Client Alert | 11 min read | 12.15.25

New York LLC Transparency Act: Key Requirements and Deadlines

On January 1, 2026 (“Effective Date”), the New York LLC Transparency Act ("New York Act”) is scheduled to take effect, introducing new disclosure requirements for limited liability companies (“LLCs”) formed or registered to do business in New York State.  The New York Act is expected to impose the type of broad beneficial ownership requirements the federal CTA and rules implementing it was designed to require, before the federal government’s decision to limit the scope of the CTA’s beneficial ownership reporting requirements to foreign companies and foreign beneficial owners....