FCA Not a Vehicle for Punishing Routine Regulatory Violations; United States Court of Appeals, District of Columbia Circuit No. 18-7123, United States ex rel. Kasowitz Benson Torres LLP v. BASF Corporation et al.

Appeal of the district court’s dismissal of an action alleging multiple chemical manufacturers violated the Toxic Substances Control Act and the FCA by withholding information from the EPA is denied, where an unassessed potential penalty for regulatory noncompliance does not constitute an obligation that gives rise to a viable FCA claim.