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Once again individual employee whistleblowers had an active year pursuing issues for the government under the False Claims Act (FCA). In 2025, FCA recoveries reached their highest mark ever at over $6.8 billion. Of that, over $5 billion came from qui tam suits filed by whistleblowers, with an increased amount coming from cases pursued by the whistleblower's private counsel after the United States declined to intervene in the litigation. One of the most significant developments for employers in 2025 came in January with Executive Order 14173 and the creation of a new Civil Rights Fraud Initiative. The initiative is designed to utilize the FCA to investigate and pursue claims against recipients of federal funds who certify compliance within civil rights laws while knowingly engaging in "diversity, equity, and inclusion (DEI) programs that assign benefits or burdens on race, ethnicity, or national origin," enact certain policies relating to gender identity, or encourage antisemitism. While the Civil Rights Fraud Initiative produced no complaints or settlements in 2025, investigations are underway, and the DOJ's comments on the matter should serve as a guidepost for companies as to how they will interpret federal anti-discrimination laws.
To keep you apprised of the current enforcement trends and the status of the law, Bradley's Government Enforcement and Investigations Practice Group is pleased to present the False Claims Act: 2025 Year in Review, our 14th annual review of significant FCA cases, developments, and trends.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
