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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 both on existing enforcement priorities such as pandemic-related fraud and healthcare enforcement actions and 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 of those areas. 

Continue Reading The Top FCA Developments of 2025
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On December 19, 2025, the Department of Justice (DOJ) announced a $54.4 million settlement with Ceratizit USA, LLC, a distributor of tungsten carbide products, resolving allegations that the company violated the False Claims Act (FCA) by evading customs duties on products imported from China. This settlement is believed to be the largest ever customs-related FCA resolution, and this high-water mark underscores the government’s heightened enforcement focus on tariff evasion.

Continue Reading Record-Setting False Claims Act Settlement Highlights DOJ Commitment to Customs Enforcement
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The facts before the Third Circuit in the recently decided case of Patel v. United States illustrate how parties can put themselves in a bind if they make factual admissions when resolving a criminal case involving fraud on the government while not simultaneously resolving the government’s civil claims under the False Claims Act (FCA) for the same underlying conduct.

Continue Reading Buying Peace: The Importance of Releasing FCA Liability When Resolving Criminal Allegations of Fraud Against the Government
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On September 30, 2025, the Department of Justice (DOJ) announced that Georgia Tech Research Corporation (GTRC) agreed to pay $875,000 to settle allegations that it violated the False Claims Act (FCA) and federal common law by failing to meet cybersecurity requirements under certain Air Force and Defense Advanced Research Projects Agency (DARPA) contracts.  The settlement adds to the growing list of recoveries under DOJ’s Civil Cyber-Fraud Initiative and is yet another example of DOJ’s ongoing enforcement focus on cybersecurity obligations for federal contractors handling sensitive government information.  The settlement also provides insight into how government contractors may challenge FCA liability when faced with allegations of cybersecurity noncompliance.

Continue Reading From Yellow Jackets to Red Flags: DOJ Stings Georgia Tech for Alleged Cybersecurity Noncompliance
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On July 31, 2025, the Department of Justice (DOJ) announced that Illumina, Inc. will pay $9.8 million to resolve allegations that it violated the False Claims Act (FCA) by selling genomic sequencing systems with software containing cybersecurity vulnerabilities to federal agencies. This is the first FCA settlement involving claims that a medical manufacturer failed to incorporate adequate product cybersecurity into its software design and development.

Continue Reading Hardening Software Security: DOJ’s Civil Cyber Fraud Settlements Continue to Illumina[te] the Importance of Cybersecurity
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On May 19, 2025, Deputy Attorney General Todd Blanche issued a Memorandum creating the Civil Rights Fraud Initiative that will “utilize the False Claims Act to investigate and . . . pursue claims against any recipient of federal funds that knowingly violates federal civil rights laws.” According to the Memorandum, though racial discrimination has “always been illegal,” the Administration posits that “many corporations and schools continue to adhere to racist policies and preferences—albeit camouflaged with cosmetic changes that disguise their discriminatory nature.” In an effort to prevent federal funds from being used in connection with or support of these purportedly racist policies and preferences, the Initiative will wield the power of the False Claims Act, the government’s most powerful tool to fight fraud, waste, and abuse.

Continue Reading DOJ’s Civil Rights Fraud Initiative Bolsters Threat of False Claims Act Enforcement Under “Anti-DEI” Executive Order
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In this episode, Crowell’s hosts Agustin Orozco and Jason Crawford speak with Crowell attorneys Simeon Yerokun and Katherine Quinn about DOJ’s plan to aggressively use the FCA against illegal foreign trade practices. This episode includes discussion of common areas of FCA enforcement in cases involving allegations of customs fraud, and the hosts address steps that

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The US Department of Justice intends to “aggressively” enforce the False Claims Act, Deputy Assistant Attorney General Michael Granston said in a speech at the Federal Bar Association’s annual qui tam conference earlier this year. He added that the agency particularly would focus on “illegal foreign trade practices” in conjunction with the Trump administration’s sweeping tariffs.

Continue Reading Aggressive FCA Enforcement in Customs Calls for Compliance Review
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United States Attorneys’ Offices recently announced a number of False Claims Act (FCA) settlements arising out of the Paycheck Protection Program (PPP). These settlements reveal several trends that PPP loan recipients should be aware of.

Continue Reading Recent Deluge of Paycheck Protection Program False Claims Act Settlements
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FY 2024 saw continued growth in False Claims Act enforcement, with a record year for new qui tam and government-initiated actions, and the highest total recovery in three years. Enforcement of pandemic-related fraud and cybersecurity noncompliance increased, and health care, procurement, and small business fraud violations were again priority areas. A groundbreaking opinion from the