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Saturday, August 23, 2025

FCA Enforcement & Compliance Digest — Summer 2025 False Claims Act Newsletter - ArentFox Schiff

In this Summer 2025 edition, we cover:

  1. Enforcement Trends: DOJ Revisions to White-Collar Crime Enforcement Priorities and Policies
  2. Enforcement Trends: Trump Administration Reinforces Illegal DEI Executive Orders With Civil Rights Fraud Initiative
  3. Litigation Developments: Insurers Under Scrutiny- Kickbacks, Discrimination, and Medicare Advantage Plans
  4. Compliance Corner: Speaker Programs for Health Care Providers- Enforcement Trends and Compliance Lessons
  5. ICYMI: DOJ Plans to Use the FCA to Attack DEI Initiatives

1. Enforcement Trends

DOJ Revisions to White-Collar Crime Enforcement Priorities and Policies

On May 12, the Criminal Division of the US Department of Justice (DOJ) introduced a new white-collar enforcement plan that overhauls the Criminal Division’s corporate enforcement priorities and updates three of its key corporate enforcement policies. The policies are (1) the Corporate Enforcement and Voluntary Self-Disclosure Policy, (2) the policy on selecting monitors, and (3) the Corporate Whistleblower Awards Pilot Program. In announcing the new plan, Matthew Galeotti, head of the DOJ’s Criminal Division, stated it “will focus the Criminal Division’s efforts on the most egregious white-collar crime to make our nation safer and more prosperous, vindicate victims’ rights, maximize the use of the Department’s resources, and provide fairness and transparency to individuals and companies alike.” However, at the American Conference Institute Conference on June 10, Galeotti...



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