Acting Associate Attorney General Jesse Panuccio, who oversees the DOJ’s affirmative-civil-enforcement litigation, including False Claims Act actions, has announced various reform projects concerning how the department will pursue cases under the FCA.
Three of these projects address how cooperation, compliance measures, and multiple-agency actions can impact FCA damages and penalties. Panuccio made perfectly clear that those who fully cooperate can expect even greater incentives. In exchange for genuine cooperation, DOJ will exercise its “tremendous enforcement discretion with respect to structuring settlements while also providing a material discount,” Panuccio says.
