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.
DOJ’s 2025 Enforcement Landscape: What Companies Need to Know
This year, the Department of Justice (DOJ) increased its focus on white-collar crime enforcement in some areas, prioritized new areas, and shifted resources away from others. Many of these changes are reflected in Acting Assistant Attorney General Matthew R. Galeotti’s May 12, 2025, memorandum to the DOJ’s Criminal Division (Galeotti Memo), which highlighted 10 high-impact areas of white-collar crime for enforcement:[1]
Courts Clash Over Qui Tam Relators and the Constitution
Recent Decisions Signal Growing Minority on Challenges to False Claims Act Constitutionality.
Background
The False Claims Act (“FCA”)’s qui tam provisions—which empower private litigants, known as “relators,” to prosecute claims on the Government’s behalf—continue to face constitutional scrutiny, with recent judicial opinions reviving concerns over whether the provisions violate Article II of the U.S. Constitution. As these challenges gain traction, qui tam defendants should be aware of the evolving legal landscape and the potential implications for FCA defense strategies.
DOJ’s Revised Corporate Enforcement Policy in Action
On May 12, 2025, the Department of Justice (DOJ) announced revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). As stated by Matthew Galeotti, head of the DOJ’s Criminal Division, the purpose of the revised CEP is to incentivize companies to “come forward, come clean, reform, and cooperate with the government in efficient investigations
DOJ’s Continued Focus on Healthcare Fraud and FCA Enforcement: What 2025 Means for Providers and Compliance Professionals
The Department of Justice (DOJ) has made it abundantly clear: healthcare fraud remains at the top of its enforcement priorities for 2025 and beyond. In a May 2025 memorandum, Acting Assistant Attorney General Matthew R. Galeotti outlined the Criminal Division’s renewed commitment to “focus, fairness, and efficiency” in the fight against white-collar crime—with healthcare
Be Careful What You Search For
As two defendants in an alleged cryptocurrency fraud case are finding out, what you search for on the internet could find its way into the courtroom and be used against you. The use of internet search history as evidence in federal criminal cases is relatively new. In this case, prosecutors are seeking to introduce defendants’ post-trade internet searches as evidence of fraudulent intent. Their searches allegedly ranged from “top crypto law firms” and “wire fraud statute” to “can your device be searched without a lawyer” and “crypto theft deductible.”
The critical question: should internet search history be admissible as evidence at trial? The answer is far from simple. Defendants generally have moved to exclude them, and the arguments for and against exclusion highlight the complex interplay between relevance, prejudice, ambiguity, and privilege.
Impact of Shutdown on Certain Federal Enforcement Agencies
There have been nearly two dozen federal government shutdowns since 1976, and while shutdowns can’t be said to be rare, it is relatively infrequent that they last very long. Only five times during that span has a shutdown lasted longer than one week. As we write this post, we are on Day 3 of the
Welcome to Husch Blackwell’s Government Enforcement, Compliance & Investigations Report
The attorneys with Husch Blackwell’s White Collar, Internal Investigations, & Compliance practice have launched this blog with one abiding goal: to provide readers with a 360-degree perspective on government enforcement. Our team possesses decades of prosecutorial and agency experience, as well as deep knowledge of how to navigate enforcement actions on behalf of clients. In