ACI: False Claims and Qui Tam Enforcement
January 29, 2026
O’Melveny partner Amanda Santella will be a guest speaker at the 13th Annual Advanced Forum on False Claims and Qui Tam Enforcement for a panel discussion entitled, “The Financials of the FCA: Damages, Penalties and Excessive Fines.”
“FCA exposure is surging, not just from treble damages but from per-claim civil penalties. FY2024 FCA settlements and judgments topped US$2.69B, while 2025’s record health care fraud takedown (criminal) spotlighted the scale of alleged losses driving civil follow-on risk. This session demystifies the numbers, the multipliers, and the growing Eight Amendment fights over the disproportionate penalties.”
Panel discussion topics include:
- Calculating total exposure by combining treble damages, current per-claim penalties, relator share, and fee-shifting
- Leveraging self-disclosure and cooperation to reduce multipliers
- Challenging disproportionate penalties under Excessive Fines Clause and tracking recent wins/losses across circuits
- Modeling settlement ranges using claim counts, sampling/extrapolation, and ability-to-pay frameworks
- Anticipating policy and inflation adjustments to FCA penalty ranges and their impact on negotiation strategy
ACI: False Claims and Qui Tam Enforcement
January 28-29, 2026
New York
The Financials of the FCA: Damages, Penalties and Excessive Fines
Thursday, January 29
3:30pm EST
Learn more and register here.