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Category Archives: Blurred Lines

Ethics and Compliance Programs: A Solution for Managing Risk

Blurred LinesBy Lorraine D'AngeloMarch 5, 2015

No matter how ethical you think your organization is, the risk of a compliance failure is there. Such a failure or lapse can result in financial, operational, and reputational harm. Some of the sanctions include assessment of huge fines, penalties or forfeiture of money, the imposition of a monitor, suspension or debarment for a period…

Blurred Lines: What the Fourth Circuit Reversal Means For Contractors

Blurred LinesBy Lorraine D'AngeloJanuary 19, 2015

The theory of implied certification under the FCA, at the appellate court level, is alive and well. On January 8, 2015, the Fourth Circuit Court in United States v. Triple Canopy, Inc. reversed a lower court decision dismissing a FCA complaint based upon a theory of implied certification. Essentially, the Fourth Circuit is allowing the case…

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