Fiscal Year (“FY”) 2025 yielded a historic high of over $6.8 billion in False Claims Act (“FCA”) settlements and judgments, underscoring the Department of Justice’s (“DOJ”) aggressive enforcement. DOJ’s annual report, released January 16, 2025, showed that healthcare fraud matters again dominated the lion’s share of the moneys recovered, accounting for more than $5.7 billion, and reaffirming the sector’s centrality to FCA priorities. Qui tam lawsuits also retained an outsized influence, representing approximately $5.3 billion in recoveries for both intervened ($3.0 billion) and declined ($2.3 billion) cases. On the flip side, that means the government recovered some $1.5 billion without the aid of an underlying whistleblower complaint. The pipeline of new cases looks robust moving forward: whistleblowers filed a record 1,297 new qui tam suits, and DOJ opened 401 new investigations.
The Civil Cyber-Fraud Initiative Delivers
Cybersecurity enforcement continued to mature, owing in part to DOJ’s Civil Cyber-Fraud Initiative, which was first announced in 2021. In the past year, $52 million were recovered across nine cybersecurity-related FCA settlements. Total recoveries have more than tripled in each of the past two years. With Cybersecurity Maturity Model Certification (“CMMC”) regulations now firmly in place, federal contractors and grant recipients must pay close attention to compliance. Although individual cyber-related settlements are modest ($5.77M on average) compared...
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