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Is proof of a defendants willfulness required to establish liability under the False Claims Act?

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Is proof of a defendants willfulness required to establish liability under the False Claims Act?

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No. Willfulness (otherwise known as criminal intent or specific intent to defraud) is not required because the False Claims Act penalizes “knowing” violations. The FCA defines “knowingly” as including actual knowledge; deliberate ignorance; and reckless disregard for the truth.

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