O’Melveny Worldwide

Amanda Santella offers her clients deep and varied expertise in government investigations and internal investigations, with a focus on False Claims Act (FCA) defense. Amanda represents a diverse array of major health insurers, life sciences companies, defense contractors, and other government contractors in all phases and stages of high-stakes FCA matters. Her work in this area includes counseling and risk assessment, internal compliance investigations, responses to government civil investigative demands and subpoenas, self-disclosures and settlements, and litigation in federal district and appellate courts. Amanda is also a frequent public speaker on FCA legal developments and enforcement trends.

In addition to her FCA practice, Amanda has represented numerous clients in congressional investigations before various House and Senate committees. Amanda’s experience with the unique demands of congressional investigations serves organizations and individual clients in these sensitive and high-profile matters as they navigate responses to congressional requests that often involve public hearings, media attention, and matters of political controversy.

Amanda’s investigations experience also includes representing corporations and individuals in connection with Anti-Kickback Statute and other Medicare enforcement investigations, criminal investigations by the Department of Justice (DOJ), and Foreign Corrupt Practices Act matters.

Get to Know Amanda

Get to Know Amanda

False Claims Act

  • Represents numerous Medicare Advantage Organizations in responding to civil investigative demands issued by DOJ in FCA investigations related to Medicare risk adjustment, Medicare Part D, the Anti-Kickback Statute, and other federal health care laws and regulations
  • Represents a major national health insurance company in federal court litigation defending against FCA allegations related to the Medicare Part D bid process 
  • Represents a large medical device manufacturer in connection with a DOJ investigation into two FCA complaints predicated on alleged violations of the Anti-Kickback Statute 
  • Represents a large transportation industry client in an FCA investigation into allegedly inflated rates charged to a government agency 
  • Represents a manufacturer of parts used in military equipment in connection with an FCA investigation into government supply chain sales
  • Represents a Medicare Advantage insurer in connection with a DOJ investigation into FCA allegations involving provider reimbursements and patient rewards 
  • Defended a major national health insurance organization against an FCA suit based on Anti-Kickback Statute allegations, from the successful dismissal of the suit through the Eleventh Circuit appeal that affirmed the dismissal with prejudice
  • Defended a major managed care organization against FCA allegations related to inflated premiums resulting from chart review practices of contracted providers and in-home assessment vendors 
  • Represented a major defense contractor in connection with a DOJ investigation into FCA allegations related to alleged labor mischarging under government contracts
  • Counsels numerous health care, life sciences, and defense contractor and subcontractor clients about the FCA risk implications of proposed business practices 
  • Counsels clients regarding Anti-Kickback Statute and Civil Monetary Penalties Law compliance issues and the attendant FCA implications 

Congressional Investigations

  • Represents former Counsel to the Vice President before the House Select Committee to Investigate the January 6 Attack on the United States Capitol
  • Represented a major national nonprofit organization in simultaneous congressional investigations by multiple House and Senate committees 
  • Represented a political committee in connection with a congressional investigation and related DOJ subpoena 
  • Represented a leading technology company in connection with a congressional inquiry regarding tax and corporate structuring issues
  • Represented a corporate client in connection with a congressional inquiry regarding implementation of the Affordable Care Act
  • Represented a major financial institution in connection with a multi-agency federal investigation and congressional investigation into a high-profile bankruptcy

Other Investigations

  • Represents corporate and individual clients in connection with criminal investigations by the Department of Justice and local United States Attorneys' Offices
  • Represents a major financial institution in an investigation by the Consumer Financial Protection Bureau 
  • Represented major national health insurer in a companywide internal investigation regarding Medicare Risk Adjustment compliance 
  • Represented a health insurer in an internal investigation related to employee allegations of Anti-Kickback Statute violations by contracted providers 
  • Represented an individual corporate executive in connection with a high-profile criminal fraud investigation
  • Represented several individuals in connection with Foreign Corrupt Practices Act investigations by DOJ and the Securities and Exchange Commission 
  • Represented a major educational institution in an internal investigation related to allegations arising from a controversial publication by a national media outlet 


Bar Admissions

  • District of Columbia
  • Maryland

Court Admissions

  • US District Court, District of Columbia
  • US Court of Appeals, Ninth and Eleventh Circuits


  • Georgetown University, J.D.: magna cum laude; Order of the Coif
  • Williams College, B.A. English

Professional Activities


  • “Cybersecurity Challenges and the False Claims Act: Insights from the SuperValu Decision,” ABA White Collar Crime Committee Newsletter, July 2023 (with Sid Mody and Hannah Dunham)
  • "2 FCA Settlements Highlight Gov't Cyber Liability Focus," Law360, May 31, 2022 (with Danny Ashby and John Dermody)
  • “Senators Introduce Bill to Curb FCA Materiality Defenses Under Escobar,” omm.com, July 27, 2021 (with David J. Leviss)
  • “Eleventh Circuit Issues Opinion Discussing Effect of Regulatory Ambiguity on Scienter,” healthlawyers.org, June 6, 2017 (with David J. Leviss)
  • “United States ex rel. Wichansky v. Zoel Holding Co.: Federal District Court Considers Definition of ‘The Government’ under the FCA,” healthlawyers.org, December 17, 2014 (with David J. Leviss)


  • Edward Bennett Williams Inn of Court 
  • Board of Trustees, Eagles Mere Association