On October 16, 2025, Jonathan Porter and I presented the second webinar in our Government Enforcement, Compliance & Investigations series—our topic: the False Claims Act (FCA). To provide background, we explained the framework of the FCA, how investigations are triggered, and notable recent FCA decisions. Then, for the second half of the hour, we discussed
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
How the FCA Has Expanded into Anti-Discrimination Enforcement
Episode 32 of the False Claims Act Insights has posted. In it, Julia Kopcienski and I discuss a recent report published by Husch Blackwell that explores the Trump administration’s demonstrated commitment to enforcing federal anti-discrimination laws through novel and varied mechanisms, like the False Claims Act. We talk about why the use of the FCA
Cybersecurity Compliance Under the False Claims Act: DOJ Enforcement, CMMC, and What Contractors Need to Know
Recent Settlements
On July 31, 2025, the DOJ announced that a California-based defense contractor, and its private equity owner Gallant Capital Partners agreed to pay $1.75 million to resolve allegations that they knowingly failed to comply with cybersecurity requirements in a contract with the Department of the Air Force. The government acknowledged that the companies
Check Out our New Monthly Webinar Series
On September 23, we launched our Government Enforcement, Compliance & Investigations webinar series, a new monthly webinar program covering Department of Justice criminal enforcement, False Claims Act, antitrust, and state attorney general topics.
In the kickoff webinar, Jody Rudman, Wendy Arends, Matt Diehr, and I joined in a broad discussion on government enforcement. Jody and I
PPP Loan Fraud Civil Enforcement through the False Claims Act
During the first eight months of 2025, our team has paid close attention to the Trump administration’s strategy for civil and criminal enforcement concerning fraud related to Paycheck Protection Program (PPP) loans. In April, Jonathan Porter and Robert Peabody discussed the Department of Justice’s use of the False Claims Act (FCA)—a civil enforcement tool—to enforce potentially criminal COVID-related fraud. In May, Rebecca Furdek, Kyle Gilster, and Emily Loftis explained the framework for ongoing PPP loan audits and investigations, followed in August by a mid-year update regarding enforcement trends and notable cases.
These and other thought leadership pieces address the origination of the PPP loan landscape during COVID-19; the rise of audits, investigations, and enforcement actions through which these and similar loans have been scrutinized; and the basic elements of the civil and criminal enforcement frameworks used to prosecute fraudulent conduct in connection with these loans.
This post explores the federal government’s ongoing efforts to combat PPP-related fraud, focusing on emerging civil enforcement trends and theories of liability under the False Claims Act.
DOJ and DHS Announce New Task Force to Counter Tariff Evasion
On August 29, 2025, the Department of Justice (DOJ) launched a new Trade Fraud Task Force, which will leverage resources from DOJ’s Civil and Criminal Divisions as well as the Department of Homeland Security (DHS) to enforce tariff and duties evasion, smuggling, and other import violations. The initiative furthers the Trump Administration’s “America First Trade Policy” announced on Inauguration Day and in Executive Order 14243, which promotes information-sharing between agencies to support the administration’s overall goals of combating waste, fraud, and abuse.
The Compliance Implications of HHS-OIG Advisory Opinions
We’ve just put the wraps on Episode 31 of the False Claims Act Insights podcast where I had a great conversation with longtime healthcare law veterans Brett McNeal and David Traskey covering advisory opinions from the Department of Health and Human Services’ Office of Inspector General. We discuss how the highly qualified and sometimes equivocal