When a Civil Investigative Demand from the Department of Justice lands on a general counsel’s desk, the reaction is often immediate alarm—and for good reason. CIDs impose tight deadlines, sweeping document demands, and significant consequences for missteps. In recent years, they also have become far more common and far more aggressive.
This isn’t hypothetical. CIDs have gone out to companies across the automotive, pharmaceutical, defense, utilities, technology, and telecommunications sectors, including demanding information about diversity programs, hiring practices, and compliance certifications.
At the Federal Bar Association’s Qui Tam Conference in February, the Justice Department reported issuing more than 1,000 CIDs annually in each of the past four fiscal years, calling that volume “the new normal.”
How a company responds in the first 30 days after receiving a CID often matters more than the merits of the underlying allegations themselves. From our experience as former assistant US attorneys, those early decisions frequently determine whether an investigation narrows, escalates, or ends.
A CID is a pre‑litigation investigative tool authorized by the False Claims Act 31 U.S.C. § 3733. It allows the government to demand documents, written responses, and oral testimony from anyone it has reason to believe may possess information relevant to a potential violation.
That threshold is deliberately low. The Justice Department isn’t required to disclose...
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