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 18 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 Relator Can’t Escape First-To-File Rule By Amending Complaint Compliance Second Circuit Defines “Willfulness” Standard Under Anti-Kickback Statute Compliance A Guide for Whistleblowers Under the False Claims Act