Civil Investigative Demand (CID)

 

 

A Civil Investigative Demand (CID) is an administrative subpoena that allows federal government agencies to request extraordinary amounts of information from private entities without going through any formal court procedures. If you have been served with a CID, you must respond promptly and appropriately in order to avoid unnecessary (and potentially severe) consequences.

 

From the U.S. Department of Justice (DOJ) and the U.S. Attorney’s Office to the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB), various federal agencies use tools known as Civil Investigative Demands (CIDs) to gather information during law enforcement investigations. Although these agencies issue CIDs in connection with civil investigations, a finding of civil liability can lead to substantial financial penalties, and the discovery of evidence of intent can quickly turn the investigation criminal.

 

As administrative subpoenas, CIDs are not subject to court approval. The DOJ, FTC, CFPB, and other agencies can issue CIDs at their discretion, and they can do so before initiating formal litigation proceedings. The grounds for challenging CIDs are very limited; and, as a result, individuals and business organizations often face extraordinary compliance obligations while having little to no information about what the federal government is investigating.

 

Typically, CIDs request the production of documents – lots of documents. In fact, for CIDs targeting healthcare providers and other businesses, it is not unusual for hundreds of thousands of paper and electronic records to be at issue. With response deadlines measured in days and weeks, not months, CID recipients must begin working to identify, collect, and prepare their responsive documents immediately.

https://federal-lawyer.com/civil-investigative-demand-cid/