Verizon’s swift response involved submitting a written self-disclosure to the GSA when the issues came to their attention. Simultaneously, they launched an independent investigation and compliance review to address the problems head-on. Subsequent detailed self-disclosures were provided to the GSA. This article delves into the confluence of factors within this settlement, examining the broader context of the DOJ’s Civil Cyber-Fraud Initiative and its stance on self-disclosure.
The Civil Cyber-Fraud Initiative
Worth noting is that this resolution is only the fourth to emerge since Deputy Attorney General Lisa Monaco unveiled the DOJ’s Civil Cyber-Fraud Initiative in October 2021. This initiative aimed to harness the DOJ’s expertise in civil fraud enforcement, government procurement, and cybersecurity to combat emerging cyber threats. Although touted with great fanfare, the DOJ has thus far announced only four resolutions under this initiative.
A singular example is the 2022 resolution of U.S. v. Aerojet Rocketdyne Holdings Inc. in the U.S. District Court for the Eastern District of California. Notably, the DOJ chose not to intervene in this case. While the combined settlements under the initiative amount to just over $14 million, this is less than 1% of the DOJ’s total FCA recoveries in 2022. Nevertheless, the Verizon settlement showcases the efficacy of the initiative.
