Crowell & Moring – False Claims Act (FCA) settlements and judgments hit record highs yet again in FY 2025, surpassing the previous record by over $1 billion and setting a new high-water mark for the number of new FCA cases filed. These records were built on existing enforcement priorities, such as pandemic-related fraud and healthcare enforcement actions, as well as on new guidance from the Executive Branch instructing the Department of Justice to enforce its 2025 priorities, including Diversity, Equity, and Inclusion (DEI), civil rights, and customs issues. Procurement fraud, cybersecurity issues, and small-business fraud also remained focal points, with significant settlements in each area.
International Development
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The Top FCA Developments of 2025
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