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.
State Attorneys General 2025 Enforcement Landscape: What Companies Need to Know
2025 marked another notable year in State Attorneys General (AG) enforcement, with both a sharp uptick in multistate AG actions filed against the federal government and significant actions targeting the private sector across industries. We will highlight two issue areas here—antitrust and consumer protection—and describe the escalating friction between State AGs and the federal government as well as distill this year’s trends into actionable takeaways for businesses as we enter 2026.
Are Qui Tams Unconstitutional? The Latest on the Zafirov Case
We just released Episode 34 of the False Claims Act Insights podcast where I had a great conversation with Jody Rudman about the new Zafirov oral argument into whether qui tams are unconstitutional. We discuss how the role of whistleblowers in the False Claims Act is unique among government whistleblower rewards programs, in that False
Government Enforcement, Compliance & Investigations Webinar Series: Trends in State Attorneys General Multistate Litigation
On December 11, Matt Diehr, Kyle Gilster, and Rebecca Furdek presented this month’s session in Husch Blackwell’s Government Enforcement, Compliance & Investigations webinar series. They highlighted the capabilities of the firm’s State Attorney’s General practice through a robust discussion about trends in multistate litigation. The presentation focused on enforcement trends in consumer
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]
Husch Blackwell Launches Congressional Investigations Practice
Husch Blackwell has formally launched its Congressional Investigations practice to assist clients across industries with all types of congressional inquiries. Our bipartisan team includes seasoned trial lawyers with specific experience in congressional investigations, former senior staff from executive branch agencies well-versed in responding to congressional inquiries, and former senior staffers from congressional committees involved in
Understanding HIPAA Disclosures When Responding to CIDs in FCA Investigations
In Episode 33 of False Claims Act Insights, Claire Postman and I tackle a critical challenge for healthcare providers: balancing HIPAA compliance with civil investigative demands (CIDs) in False Claims Act investigations. Claire explains HIPAA’s general prohibition on disclosing protected health information and the key exceptions that permit disclosure when required by law, such as
The Growing Liability Risk of State False Claims Act Statutes
Todd Gee and I recently published an article in Risk Management, discussing in detail the growing risk of state-level False Claims Act (FCA) enforcement for state government contractors and recipients of state funds or benefits. While many government funding recipients are familiar with the federal FCA, state legislatures across the nation are either establishing—or
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.
Government Enforcement, Compliance & Investigations Webinar Series: Update in Antitrust Enforcement
On November 12, 2025, Wendy Arends and Mark Tobey presented the latest session in Husch Blackwell’s Government Enforcement, Compliance & Investigations webinar series. They discussed current updates in antitrust enforcement in detail. Covering federal and state merger enforcement first—one key takeaway at the federal level, the agencies continue to take HSR and Second Request compliance