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Michael Granston

Michael Granston, Chair of Covington’s False Claims Act Investigations and Litigation practice, spent nearly three decades at the Department of Justice (“DOJ”) and for the last six years served as Deputy Assistant Attorney General, the highest-ranking career employee in the Civil Division.

Michael advanced through the ranks within the Civil Fraud Section, beginning his DOJ career as a Trial Attorney, and eventually serving as Director from 2013 to 2019. As Director, he oversaw the Department’s pursuit of False Claims Act (“FCA”) investigations and litigation, as well as other actions relating to fraud, kickbacks, and conflicts of interest.

Michael most recently served as Deputy Assistant Attorney General starting in 2019. In this capacity, he managed not only the Civil Fraud Section but also all aspects of the Commercial Litigation Branch, including litigation in areas such as international trade, intellectual property, bankruptcy, and bid protests.

During his tenure at DOJ, Michael supervised many of the most significant FCA matters while playing a primary role in formulating the Department’s FCA priorities and policies. He spearheaded DOJ’s approach to major statutory changes in 2009 and 2010 to the FCA and its qui tam provisions. He also was instrumental in developing various DOJ guidance on the investigation and handling of FCA matters, including most notably a 2018 memorandum that clarified when DOJ should consider dismissing non-intervened whistleblower suits—commonly referred to as the “Granston Memorandum.” Michael helped identify and advance key enforcement priorities under the FCA across multiple administrations, including fraud involving prescription opioids, the Medicare Part C and D programs, the Anti-Kickback and Stark Statutes, government contracts and grants, cybersecurity issues, and trade and customs laws.

Michael also served as the Civil Division’s Chief Ethics Officer and was a member of the State Secrets Review Committee.

On January 23, 2026, Vice President Vance announced the administration’s intent to expand the “Mexico City Policy.”  First established by President Reagan, the Mexico City Policy originally prohibited foreign non-governmental organizations (“NGOs”) from using funds to “promote abortion as a method of family planning in other nations.”  The policy was repealed by the Biden administration but then reinstated at the outset of the current administration.  On January 27, 2026, the State Department implemented the Vice President’s announcement, and expanded the Mexico City Policy to require recipients of “foreign assistance” to abide by award terms reflecting three new policies: (1) Protecting Life in Foreign Assistance (“PLFA”); (2) Combating Gender Ideology in Foreign Assistance (“CGIFA”); and (3) Combating Discriminatory Equity Ideology in Foreign Assistance (“CDEIFA”).[1]

Collectively, the new PLFA, CGIFA, and CDEIFA policies are referred to as the Promoting Human Flourishing in Foreign Assistance policy (“PHFFA”).  These rules create new obligations relevant to U.S. NGOs, foreign NGOs, and other international organizations receiving foreign assistance. This blog post focuses on the new CDEIFA requirements—and the potential pitfalls—for U.S. NGOs.Continue Reading State Department Revives and Expands the Mexico City Policy

On September 18, 2025, the Department of Justice (“DOJ”) announced a civil False Claims Act (“FCA”) settlement against a New Jersey shipbuilder to resolve allegations that it improperly employed unauthorized workers to work on Navy ships.  The settlement, which exceeded $4 million, is the second this year involving government contractors alleged to have employed unauthorized workers in violation of FAR 52.222-54, Employment Eligibility Verification.  With immigration enforcement squarely at the center of the current administration’s domestic agenda, government contractors should be mindful of this enforcement theory and take appropriate steps to ensure compliance and protect themselves from a costly FCA claim. Continue Reading E-Verify and the False Claims Act: An Emerging Tool in Immigration Enforcement