United States ex rel. TZAC, Inc. v. Christian Aid and the Limits of Personal Jurisdiction in False Claims Act Cases
Recently, in United States ex rel. TZAC, Inc. v. Christian Aid, a federal district court in New York dismissed a False Claims Act (“FCA”) qui tam case for lack of personal jurisdiction over a U.K. nongovernmental organization (“NGO”).
According to the relator, The Zionist Advocacy Center (“TZAC”), Christian Aid received $26,000 in grant monies from the United States Agency for International Development (“USAID”) to conduct jobs training for disabled people in Lebanon. Christian Aid allegedly received its USAID grant monies on condition of signing Anti-Terrorism Certifications attesting that it did not provide material support to terrorists. TZAC alleged that the certifications were false because, in 2015, Christian Aid worked with an organization in Lebanon that had been designated by the U.S. government as a “Foreign Terrorist Organization.”
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