On August 25, 2026, the U.S. Department of Justice (DOJ or the Department) announced a $21.5 million settlement with Deloitte LLP and four affiliated entities (collectively, Deloitte), marking the second False Claims Act (FCA) settlement under the Department's Civil Rights Fraud Initiative launched in May 2025. The settlement resolves allegations that Deloitte violated the FCA by falsely certifying compliance with anti-discrimination requirements in its federal contracts while engaging in challenged race- and sex-based employment practices and charging costs relating to these practices to federal government contracts. This case follows the $17 million IBM settlement announced in April 2026 and confirms that DOJ's enforcement in this area remains active.
The resolution with Deloitte is notable for both its similarities to the IBM settlement and key differences, summarized below.
Comparison to IBM Settlement
Monetary Terms – While the settlement amount with Deloitte is greater than that with IBM ($21.5 million compared to approximately $17 million), the payment is described in similar terms as “inclusive of civil penalties.” Neither agreement specifies the amount of the settlement attributable to penalties versus damages.
Scope of Allegations – The settlement with Deloitte spans a broader time, going back nearly 10 years to January 2017, compared to 2019 in the IBM settlement. Nonetheless, the government asserts the same two bases of alleged liability, namely that Deloitte...
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