The U.S. Treasury can now rely on recovering a billion dollars each year from antifraud efforts. Enacted during the Civil War to combat war profiteering, (1) the False Claims Act (FCA) prohibits the submission of false or fraudulent claims for payment to the United States? An individual violates the FCA when he "knowingly presents, or causes to be presented" to the government "a false or fraudulent claim for payment or approval," (3) or "knowingly makes, uses, or causes to be made or used, a false record or statement to get a false or fraudulent claim paid or approved by the Government." (4) A defendant acts "knowingly" if he acts with "actual knowledge," "deliberate ...