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You didn't see it coming. Your company took a supporting role in a federally funded program such as Medicare, or supported a prime contractor to a defense or civilian agency. Your company is certain it never submitted a false invoice, never certified compliance with any federal requirements, and never promised to comply with federal regulations.
Out of the blue, the Department of Justice (DOJ) contacts you about a qui tam complaint alleging your company submitted “false claims” involving federal funds and is liable for treble damages, plus penalties under the civil False Claims Act, 31 U.S.C. 3729 (FCA). You think: “This cannot be happening to my company.”
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