On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum concerning a “Civil Rights Fraud Initiative” and announcing it would “utilize the False Claims Act to investigate and, as appropriate, pursue claims against any recipient of federal funds that knowingly violates federal civil rights laws.” The FCA is the U.S. government’s primary enforcement tool in connection with recipients of federal funds. FCA liability can be enormous, with treble damages and significant per claim penalties. Employers who receive federal funding, whether directly or indirectly and whether by contract or grant, need to be thoughtful before signing any certification of compliance with federal laws that may be viewed to include an expressed or implied certification of compliance with federal civil rights laws. Read the full Alert on the Duane Morris website.