The False Claims Act continues to be a powerful enforcement tool, with nearly $3 billion recovered in 2024 alone. Maria Durant and Gejaa Gobena of Hogan Lovells analyze emerging trends, including the new administration’s approach to whistleblower cases, the role of DOGE in identifying fraud and the double-edged sword of AI in both creating and detecting potential violations.
2024 was another massive year for False Claims Act (FCA) enforcement with the DOJ reporting nearly $3 billion in recoveries for the fiscal year. The 558 settlements and judgments achieved in 2024 — the second-highest behind 2023 — reflect the government’s enforcement priorities, including combating healthcare fraud, fraud in pandemic relief programs and knowing violations of cybersecurity requirements in government contracts and grants.
Of the nearly $3 billion recovered, over $2.4 billion arose from qui tam suits pursued by either the government or relators. And, ensuring continued activity in the months to come, whistleblowers filed 979 qui tam lawsuits in FY2024, the highest ever in a single year.
Looking ahead to 2025, Attorney General Pam Bondi joins the DOJ after serving as Florida’s attorney general, where her team participated actively and frequently in multistate qui tam investigations, litigation and settlements.
Given that prosecuting fraud, waste and abuse enjoys strong bipartisan support both from Congress and the American taxpayers, one should expect that the FCA will remain a critical...
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