Home Compliance Second Circuit Explicates Scienter Element of Anti-Kickback Violation. How Willful Must the... ComplianceFCAResource Library Second Circuit Explicates Scienter Element of Anti-Kickback Violation. How Willful Must the Kickback Be? March 14, 2024 28 Share FacebookLinkedinTwitter Yeexin Richelle | Shutterstock You must be a Paid or Free Trial Member to Access this Content. Paid members, please login to view your news subscription(s). RELATED ARTICLESMORE FROM AUTHOR Compliance Series on Healthcare Fraud Risk for The Compliance & Ethics Blog Compliance Chevron’s Demise Creates New False Claims Act Defenses Compliance Wave of the Future: Are AI and Data Mining the Next Generation of “Professional Whistleblowers”?