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DOJ Enforcement Actions

					
The  is the principal federal agency authorized to enforce the laws and defend the interests of the United States. As such, it oversees the enforcement of the False Claims Act, the foundation of the American whistleblower system, as well as numerous other laws.


The agency traces its origins to the Judiciary Act of 1789 which created the Office of the Attorney General, and the 1870 Act to Establish the Department of Justice, which established the agency as “an executive department of the government of the United States” with the Attorney General as its head.


The agency is comprised of numerous divisions with the Civil Division and in some instances, the Criminal Division, overseeing investigations and prosecutions under the False Claims Act. The  of the federal district where the False Claims Act case is filed also plays a key role in False Claims Act enforcement.


Below are summaries of recent DOJ settlements or successful resolutions under the False Claims Act as well as other successful prosecutions for fraud and misconduct. If you believe you have information about fraud which could give  rise to a claim for a whistleblower reward, please contact us to speak with one of our experienced whistleblower attorneys.

				

			

			
						
					
			

	
		
		

			

				
				
January 14, 2022

				 Perry Santillo was sentenced to 17.5 years in prison and ordered to pay restitution of more than $100 million following his conviction on charges related to fraudulent investment schemes including the solicitation of funds through and for Lucian Development and City Capital Corporation.  The Ponzi scheme, which operated over ten years, obtained at least $115.5 million from approximately 1000 investors. Santillo and his co-conspirators purchased the businesses of investment advisors and brokers around the country in order to find potential new investors, and used new investments to fund their lavish lifestyles and make interest and other payments to earlier investors.  (related co-defendant)				 					 

						
Tagged in:
													  Criminal Proceedings, 
													  Financial and Investment Fraud, 
													  Misrepresentations, 
													  Ponzi Schemes, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 14, 2022

				 A former official with the Department of Defense’s Office of Inspector General who was accused of accepting bribes on a prime contract and defrauding the government has been sentenced to 7.5 years in prison.  While overseeing a contract that allowed federal agencies in the DC area to order telecommunication services and equipment, Matthew LumHo solicited and received bribes from a co-conspirator, William S. Wilson, in exchange for steering business to Wilson’s company.  Lumho also knowingly authorized fraudulent service orders for marked up services—essentially defrauding the government into paying for the bribes themselves—and repeatedly interfered with the criminal investigation.  				 					 

						
Tagged in:
													  Bribery and Bid-Rigging, 
													  Criminal Proceedings, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 14, 2022

				 Conduent Education Services LLC, f/k/a Xerox Education Services LLC, d/b/a ACS Education Services LLC (CES)—a contractor that serviced student loans for lenders—has agreed to pay $7.9 million to resolve allegations of submitting or causing the submission of false claims to the Department of Education (DOE) between 2006 and 2016.  In violation of Federal Family Education Loan (FFEL) program rules and the False Claims Act, CES allegedly failed to accurately report required data on the impact of monthly student loan repayments, principal capitalization, and other changes to DOE.  Under a prior remediation plan, CES paid DOE $1.4 million to partially resolve its liability, which it received credit for in the current settlement.  				 					 

						
Tagged in:
													  Education Fraud, 
													  FCA Federal, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 12, 2022

				 Six medical practices affiliated with Interventional Pain Management Center P.C. (IPMC), as well as physician-owner Dr. Amit Poonia, have agreed to pay nearly $7.5 million to resolve allegations of defrauding Medicare and the Federal Employees Health Benefit Program.  In a qui tam suit by Anu Doddapaneni and Christian Reyes, the whistleblowers alleged that Poonia and IPMC violated the False Claims Act by using a billing code that mischaracterized P-Stim and NeuroStim treatments—which transmit electrical pulses through needles placed just under the skin of a patient’s ear—as surgical implantation requiring anesthesia.  				 					 

						
Tagged in:
													  FCA Federal, 
													  Healthcare Fraud, 
													  Medical Billing Fraud, 
													  Medicare, 
													  Misrepresentations, 
													  Other Government Health Programs, 
													  Provider Fraud, 
													  Whistleblower Case, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 12, 2022

				 A diabetic shoe company, Foot Care Store, Inc., d/b/a Dia-Foot, and its President and CEO, Robert Gaynor, have agreed to pay $5.5 million to resolve allegations of billing Medicare and Medicaid for custom diabetic shoe inserts when in fact, their inserts were made using generic foot models.  The alleged misconduct occurred between 2013 and 2018 and was revealed in a whistleblower’s 2018 qui tam suit.  In addition to the monetary penalty, Dia-Foot has entered into a three-year Integrity Agreement that requires the company to implement updated policies and procedures and submit to quarterly independent review of its claims to Medicare and Medicaid.  				 					 

						
Tagged in:
													  FCA Federal, 
													  Healthcare Fraud, 
													  Medical Devices and DME, 
													  Medicare, 
													  Whistleblower Case, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 12, 2022

				 Idaho-based Native American Services Corp. (NASCO) and Texas-based Mirador Enterprises, Inc. (Mirador) have agreed to pay $750,000 and $400,000 respectively, for a combined settlement of $1.15 million, to resolve allegations of fraudulently obtaining two construction contracts at Colorado’s Fort Carson Army installation.  According to the DOJ, one contract was set aside for eligible economically and socially disadvantaged small businesses, and the other was set aside for eligible small businesses.  Although Mirador was eligible for both contracts, it allowed its mentor NASCO to take on the primary role in the performance of the contracts; both companies then took steps to conceal the fraud.  				 					 

						
Tagged in:
													  Contract Non-Compliance, 
													  Defense Contract Fraud, 
													  FCA Federal, 
													  Government Procurement Fraud, 
													  Set-Asides and Preferences, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 11, 2022

				 A man who orchestrated a $10 million tobacco excise tax evasion scheme against the State of Washington, engaged in money-laundering, and evaded $850,000 in federal income taxes has been sentenced to a little over 2 years in prison and ordered to pay $5 million in restitution.  Through his company, TC MAC, Hyung Il Kwon of Nevada purchased significant quantities of tobacco in cash, failed to report the purchases to the state, and subsequently resold the products for cash.  In order to avoid alerting the state to large cash deposits, Kwon then laundered the money by writing checks in exchange for large amounts of cash.  Kwon has a prior state conviction for similar charges.  				 					 

						
Tagged in:
													  Criminal Proceedings, 
													  Tax Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 11, 2022

				 UC San Diego Health has agreed to pay $2.98 million to resolve allegations that it ordered and submitted referrals for medically unnecessary genetic testing, leading to the submission of false claims to Medicare.  				 					 

						
Tagged in:
													  FCA Federal, 
													  Healthcare Fraud, 
													  Lack of Medical Necessity, 
													  Medicare, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 10, 2022

				 Following his guilty plea on charges related to the filing of false tax returns claiming nonexistent fuel tax credits, Michael Dexter Little was ordered to forfeit $12.3 million and sentenced to 19.5 years in prison.  Little and his fellow fraudsters filed false tax returns in their own names and in the names of identity theft victims, and laundered the proceeds via real estate and other assets. 				 					 

						
Tagged in:
													  Criminal Proceedings, 
													  Environmental Fraud, 
													  Tax Credit and Deduction Fraud, 
													  Tax Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 6, 2022

				 SoNo International LLC and Ark Capital Equipment LLC have agreed to pay $904,000 to resolve allegations of supplying the Department of Defense with shipping containers that were made in China or made of Chinese steel, in violation of contracts as well as the False Claims Act.  As part of the settlement, the two companies will also submit to enhanced training and reporting requirements pursuant to an administrative agreement with the Defense Logistics Agency.  An unnamed third-party company, which SoNo and Ark hired to change identifying plates on the shipping containers, has separately agreed to train employees on customs rules and regulations.  				 					 

						
Tagged in:
													  Contract Non-Compliance, 
													  Defense Contract Fraud, 
													  FCA Federal, 
													  Government Procurement Fraud, 
													  Trade Agreements, 
												
						

					
	
							
	
		
		
	


 			


											

						

								

									
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