Executive Summary

For decades, the False Claims Act (FCA) has served as the government’s primary tool for combating fraud involving federal funds. FCA enforcement has historically focused on well-established fraud theories such as overbilling, defective pricing, medically unnecessary services, and the submission of false invoices. However, over the last decade, the government and relators have increasingly advanced more novel and expansive theories of FCA liability, reflecting an evolution in enforcement priorities and a willingness to test the statute’s boundaries.

That evolution has been accompanied by significant enhancements in enforcement capabilities. Today, the Department of Justice (DOJ) is increasingly leveraging artificial intelligence (AI), data analytics, interagency information-sharing, and specialized enforcement task forces to identify potential FCA violations. At the same time, DOJ has expanded its focus to a broader range of compliance-related conduct. This heightened enforcement landscape has coincided with record-breaking FCA recoveries. In January 2026, DOJ reported US$6.8 billion in FCA recoveries for Fiscal Year (FY) 2025, marking the largest annual total to date.¹

While healthcare-related matters continue to account for a substantial share of recoveries, procurement fraud remains a major enforcement priority. In FY 2025, DOJ secured its second-largest procurement fraud recovery in history, when a federal contractor agreed to pay US$428 million to...

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