To act 'willfully' within the meaning of the Anti-Kickback Statute, must a defendant know that its conduct violates the law?

QUESTION PRESENTED The Anti-Kickback Statute prohibits, among other things, “knowingly and willfully offer[ing] or pay[ing] any remuneration (including any kickback, bribe, or rebate) directly or indirectly, overtly or covertly, in cash or in kind to any person to induce such person ... to purchase ... any good, facility, service, or item for which payment may be made in whole or in part under a Federal health care program.” 42 U.S.C. § 1320a-7b(b)(2)(B). To violate the Anti-Kickback Statute, a “person need not have actual knowledge of [the Statute] or specific intent to commit a violation of” it. Id. § 13820a-7b(h). The question presented is: To act “willfully” within the meaning of the AntiKickback Statute, must a defendant know that its conduct violates the law?