This was intentional criminal conduct of conspiracy and perjury related to Anti-Kickback Statute violations. From a U.S. Attorney’s Office for the Eastern District of Texas Press Release:
“By facilitating kickbacks, this defendant knowingly enabled theft from Medicare and Medicaid, putting personal profit before legitimate patient needs and ultimately costing taxpayers millions of dollars,” said Jason E. Meadows, Special Agent in Charge at the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG). …
According to information presented in court, [Peter J. Bennett] created sham trusts and shell corporations through which he laundered at least $2,724,080.41 in healthcare kickback proceeds. Bennett used his law firm’s Interest on Lawyers Trust Account (IOLTA), operating account, and a personal bank account to launder and transmit the kickback proceeds. The perjury charges arose out of false statements Bennett made in response to interrogatories propounded in Civil Investigative Demands issued by the Department of Justice as part of a False Claims Act (FCA) investigation. Bennett was indicted by a federal grand jury in February 2022.