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Although Department of Justice ( DOJ ) recoveries
under the False Claims Act ( FCA ) reached historic lows
in fiscal year 2020, President Biden s administration is poised
to usher in a return to aggressive FCA enforcement. Under President
Obama, DOJ s FCA recoveries hit all-time peaks, totaling over
$5 billion in 2012, $6.1 billion in 2014, and $4.9 billion in 2016.
From there, they trended consistently downward throughout the Trump
Administration, averaging under $3 billion annually. Given the
Biden Administration s focus on tackling the COVID-19 pandemic
and stimulating the economy, we anticipate that DOJ s scrutiny
of alleged fraud in government programs will be as probing as
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