Deputy Associate Attorney General Stephen Cox in recent remarks offered some key insight into the Department of Justice’s enforcement principles, policies, and perspectives that guide its False Claims Act enforcement—covering everything from the Granston Memo to sub-regulatory guidance and its policy discouraging “piling on.”
At the 2019 Advanced Forum on False Claims and Qui Tam Enforcement on Jan. 28, Cox began his remarks by talking about the Granston Memo, internal guidelines issued last January by the Director of the Civil Fraud Section instructing its lawyers to consider dismissing whistleblower cases when they are not in the Department’s best interests.
Of the $2.8 billion in FCA recoveries...