The first half of 2026 has confirmed that False Claims Act (FCA) enforcement is not only continuing at historically elevated levels but is expanding in scope, sophistication, and institutional backing. With the Department of Justice (DOJ) reporting more than $6.8 billion in FCA settlements and judgments for fiscal year 2025 (the highest annual total on record) and qui tam filings on pace to set another record in FY 2026, federal fund recipients across various industries face a sustained period of heightened scrutiny. This mid-year update synthesizes the most significant developments and offers practical considerations for navigating the current enforcement landscape.




