When the second Trump administration took office, many legal commentators anticipated major changes to the Department of Justice's (DOJ) enforcement efforts. Some declared federal white-collar enforcement dead as the administration paused Foreign Corrupt Practices Act enforcement in February 2025. But on January 16, 2026, DOJ announced a record-breaking $6.8 billion in False Claims Act (FCA) settlements and judgements recovered in fiscal year (FY) 2025. This staggering figure more than doubles 2024's $3.1 billion in FCA recoveries. The announcement from DOJ also reflected a 17 percent increase in new FCA matters from the previous fiscal year. Clearly, reports of white-collar enforcement's demise were greatly exaggerated. FCA enforcement is alive and flourishing, as DOJ is aggressively pursuing fraud claims across multiple sectors of government contracting beyond traditional health care fraud, from civil rights fraud to trade fraud and beyond.
As in past years, most FCA complaints were filed by qui tam relators. This is not surprising. The Attorney General stated her support for qui tam suits in January 2025 during her confirmation hearing. The sentiment was emphasized in May 2025 when DOJ "strongly encourage[d] anyone with knowledge" to file under the FCA, and further encouragement came in August 2025, when DOJ announced the Trade Fraud Task Force, calling on whistleblowers to "utilize qui tam provisions . . . to alert the government to...
When the second Trump administration took office, many legal commentators anticipated major changes to the Department of Justice's (DOJ) enforcement efforts. Some declared federal white-collar enfo...