Hidden Dangers Lurking in Corporate Integrity Agreements
- February 19, 2025
- Federal False Claims Act
When I litigated False Claims Act (FCA) cases at the U.S. Department of Justice (DOJ), it was common practice for settlements to require Corporate Integrity Agreements (CIAs) setting forth ongoing duties and responsibilities for corporate defendants entering a settlement with the DOJ. Sometimes, those CIAs included stipulated penalty provisions, which establish set penalty amounts for violations of the terms of the CIA.