2025 has been a landmark year for False Claims Act (FCA) enforcement, marked by record-breaking settlements, evolving legal theories, and a broadening scope of government priorities. The FCA remains one of the federal government’s most potent tools for combating fraud, with billions recovered annually and an ever-expanding reach into new sectors and compliance areas. This roundup synthesizes the year’s most significant developments—drawing on recent case law and shifting enforcement priorities—and provides actionable insights for businesses navigating the FCA landscape.
Case Law Update: Constitutional Challenges and Qui Tam Relators
In 2025, the constitutionality of the FCA’s qui tam provisions—which empower private litigants (relators) to prosecute fraud claims on the government’s behalf—continued to emerge as a focal point of judicial debate. Historically, federal courts, including the U.S. Court of Appeals for the Fifth, Sixth, Ninth, and Tenth Circuits, have rejected arguments challenging the constitutionality of qui tam actions, emphasizing that the government retains significant control over litigation even when a relator pursues a case independently. Recent district court decisions often emphasize the FCA’s longstanding role in federal fraud enforcement.
However, a district court decision in the Middle District of Florida in United States ex rel. Zafirov v. Fla. Med. Assocs., LLC held that the FCA’s qui tam provisions violate the Appointments Clause in Article II of...
The Cambodian Interior Ministry has firmly rejected misleading reports from the Thai news outlet Khaosod English, which alleged that Thai Marines had seized a significant cache of Cambodian arms a...