We previously offered insight into two False Claims Act ("FCA") enforcement actions brought by the U.S. Department of Justice ("DOJ") as part of its "Civil Cyber-Fraud Initiative" ("CCF Initiative"). Deputy Attorney General Lisa O. Monaco announced the CCF Initiative in October 2021, stating that "[t]he initiative will hold accountable entities or individuals that put U.S. information or systems at risk by knowingly providing deficient cybersecurity products or services, knowingly misrepresenting their cybersecurity practices or protocols, or knowingly violating obligations to monitor and report cybersecurity incidents and breaches." We noted that DOJ "was not bluffing," and that in addition to the two highlighted cases, "more are expected." The prediction has come true.
DOJ recently announced a settlement with Jelly Bean Communications Design LLC and its sole employee, manager, and 50% owner (collectively, "Jelly Bean"), whereby Jelly Bean agreed to pay nearly $300,000 to resolve cybersecurity-related FCA claims. Of that amount, $130,565 constituted restitution, and thus, the company paid a significant multiplier penalty as well (the FCA allows for treble damages plus substantial additional civil penalties for each false claim; impacted agencies have exclusion authority as well). DOJ alleged that Jelly Bean created, hosted, and maintained a website for the Florida Health Kids Corporation ("FHKC"), a state-created and federally funded entity that offers health and dental...
Published on April 28, 2026 In a determined effort to protect the reputation of one of Africa’s most iconic wildlife destinations, Kenya’s Tourism Regulatory Authority has strongly denied false cl...