How The New FCA Cooperation Credit Guidelines Fall Short

By Craig Margolis and Christian Sheehan (May 10, 2019, 2:31 PM EDT) -- The thing about a grab bag or the proverbial box of chocolates is that you never know what you are going to get. On May 7, 2019, the U.S. Department of Justice's published formal guidelines presaged by Deputy Attorney General Rod Rosenstein in a November 2018 speech on cooperation credit in False Claims Act cases.[1] And while we applaud the department's putting pen to paper on FCA enforcement guidance, we are left scratching our collective heads on what's in the offing....

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