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Key Takeaways
- False Claims Act (FCA) settlements and judgements in Fiscal Year (FY) 2025 exceeded $6.8 billion, marking the largest-ever recovery in the history of the FCA.
- There were 1,297 qui tam whistleblower lawsuits filed, the highest number in a single year.
- Key enforcement priorities included: (1) healthcare fraud, accounting for more than 83 percent of the total recoveries; (2) government and military contracting fraud, including cybersecurity fraud; and (3) tariff and customs evasion fraud.
On January 16, 2026, the U.S. Department of Justice (DOJ) announced it had recovered more than $6.8 billion in FCA settlements and judgments for FY 2025.1 This record-breaking figure marked the largest annual total in the statute's history, more than doubling last year's total of $2.9 billion in FY 2024.
The DOJ reported that whistleblower qui tam lawsuits accounted for a significant portion of the total recoveries, with $5.34 billion recovered from both intervened and non-intervened cases, or approximately 78 percent of the total FCA recoveries in 2025. Notable qui tam recoveries included a $1.6 billion verdict from the District of New Jersey involving alleged false prescription drug claims, and a $289 million verdict from the Eastern District of Pennsylvania involving alleged inflated drug prices. By statute, eligible qui tam whistleblowers receive a portion of the recovery ranging from 15 percent to 30 percent, incentivizing private individuals to file suit. A record 1,297 new qui tam lawsuits were filed in FY 2025, up from 980 filed in FY 2024.
Key Enforcement Priorities
The DOJ also highlighted several key enforcement areas in 2025 that it will continue to prioritize going into 2026. These include:
Health Care Fraud – The health care industry continues to be a major area of enforcement with more than $5.7 billion recovered in FY 2025, or 83 percent of the total FCA recoveries. Specifically, the DOJ focused on allegations relating to managed care (or Medicare Advantage), prescription drugs (e.g., drug pricing, dispensing, and kickbacks), and medically unnecessary care.
Government and Military Contracting – The DOJ also focused on alleged fraud involving military procurement contracts. For example, the DOJ referenced several matters involving allegations of false and inflated costs to the U.S. military for contracts essential for defense systems and equipment, including a $428 million settlement, the second-largest procurement fraud case in the DOJ's history.
Tariffs and Customs Avoidance – The DOJ is also prioritizing combatting alleged fraud related to tariffs and customs duties (e.g., misrepresenting the type of goods imported or an item's country of origin, or disguising items to evade duties). In particular, on August 29, 2025, the DOJ launched a cross-agency Trade Fraud Task Force to strengthen its enforcement against tariff evasion.2 Of note, the DOJ recently entered into a $54.4 million settlement with a distributor of tungsten carbide products to resolve FCA allegations that the company had failed to pay duties on products imported from the People's Republic of China.3
Cybersecurity – The DOJ also highlighted the importance of compliance with essential government contract terms relating to cybersecurity, to ensure the security of government information. More than $52 million was recovered in nine cybersecurity fraud settlements, tripling the settlement amounts in each of the past two years.
Pandemic Relief Fraud – The DOJ continues to crack down on fraud allegations related to improper payments under the Paycheck Protection Program (PPP), as well as fraud related to COVID-19 testing and treatment. The DOJ recovered more than $230 million in FY 2025 for pandemic-related fraud.
Takeaways
Deputy Attorney General Todd Blanche stated in the press release that "this record-breaking year proves the False Claims Act remains one of the government's most powerful weapons against fraud" and that the DOJ "will continue to aggressively deploy it to protect taxpayer dollars and hold all fraudsters accountable."
This press release and the underlying level of increased enforcement activity signal the DOJ's aggressive use of the FCA going into 2026, with potentially more investigations and qui tam lawsuits to come given their success in FY 2025. There will likely be a rise in enforcement matters related to alleged tariff and custom evasion, government contracting and cybersecurity, and a continued focus on the health care industry, in particular Medicare Advantage. As such, entities and individuals in these key industries should reassess and strengthen their compliance programs and analyze potential areas of risk.
Our experienced team of False Claims Act attorneys and industry experts, including former U.S. Attorneys, Assistant U.S. Attorneys, and other government regulatory lawyers, have successfully defended and prosecuted these issues from start to finish.
Footnotes
1 https://www.justice.gov/opa/pr/false-claims-act-settlements-and-judgments-exceed-68b-fiscal-year-2025
2 https://www.justice.gov/opa/pr/departments-justice-and-homeland-security-partnering-cross-agency-trade-fraud-task-force
3 https://www.justice.gov/opa/pr/ceratizit-usa-llc-agrees-pay-544m-settle-false-claims-act-allegations-relating-evaded-0
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