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Unanimous Supreme Court Cabins Wartime Suspension of Limitations Act

Client Alert | 1 min read | 05.27.15

The Supreme Court on Tuesday handed down KBR v. U.S. ex rel. Carter, in which it unanimously reversed the Fourth Circuit's interpretation of the Wartime Suspension of Limitations Act, whose text, structure, and history all show it to be limited to criminal offenses—it does not toll the statute of limitations on civil FCA cases. The Court also unanimously affirmed the Fourth Circuit's interpretation of the FCA's first-to-file bar, and thus resolved a split with the D.C. Circuit, by holding that a qui tam complaint that has been dismissed is no longer "pending" within the meaning of the bar and, therefore, will not preclude future, related actions.


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....