This update summarizes noteworthy enforcement activity from the first six months of 2026. We discuss significant federal policy and state legislative developments, including the current status of state false claims statutes. We also analyze the most consequential court decisions of the first half of the year.
The first half of 2026 confirmed not only the False Claims Act (FCA)’s entrenched status as the federal government’s principal civil fraud enforcement tool, but also the depth and breadth of the current Administration’s efforts to use the statute to pursue its policy and political goals. Thus far, 2026 has—like many years before it—borne witness to significant recoveries across industries. All told, the FCA settlements and judgments announced during the first half of 2026 and discussed below total more than $1.8 billion. These included two nine-figure resolutions in the Medicare Advantage space, and a more than half-billion-dollar settlement related to customs duties (the largest ever). DOJ’s track record thus far this year means it could be on pace to exceed the $2.9 billion DOJ reported in FCA settlements and judgments for FY 2024, although it remains to be seen whether DOJ will break the $6.8 billion it reported for FY 2025. At the same time, DOJ reached its first-ever settlement on an anti-discrimination theory since the establishment of the Civil Rights Fraud Initiative last year, and publicly and in significant detail explained the theories it is pursuing, and...
This update summarizes noteworthy enforcement activity from the first six months of 2026. We discuss significant federal policy and state legislative developments, including the current status of s...