False Claims Act Enforcement Reaches Record $6.8 Billion in Recoveries for 2025

False Claims Act (FCA) enforcement reached unprecedented heights in 2025, with government recoveries exceeding $6.8 billion—the highest total in the law’s history. This record-breaking figure underscores the FCA’s continued prominence as one of the federal government’s most powerful tools for combating fraud in government programs.

The year witnessed more FCA cases filed than any previous period, according to a comprehensive analysis by Bradley’s Government Enforcement and Investigations Practice Group. While many established patterns continued, the government expanded its focus to include new areas such as customs enforcement and diversity, equity, and inclusion (DEI) initiatives.

Healthcare remained the dominant sector for FCA enforcement, accounting for approximately 84% of total recoveries. This industry’s overwhelming representation highlights the ongoing scrutiny faced by healthcare providers, pharmaceutical companies, and medical device manufacturers in their interactions with federal healthcare programs like Medicare and Medicaid.

The government maintained its strategy of leveraging Anti-Kickback Statute (AKS) violations as the foundation for FCA liability. This approach has prompted judicial debate regarding the appropriate causation standard to apply in such cases, creating important precedents that companies operating in regulated industries must navigate carefully.

A notable trend that gained momentum in 2025 was the constitutional questioning of the FCA’s qui tam provisions, which allow private citizens (known as relators) to file lawsuits on behalf of the government and share in any financial recovery. Two judges from the Fifth Circuit Court of Appeals added their perspectives to this ongoing debate, while opinions are anticipated from both the Eleventh and Third Circuit Courts in the coming months.

Legal experts suggest this constitutional scrutiny could significantly reshape the landscape of FCA enforcement if courts begin limiting the ability of qui tam relators to bring cases. Since whistleblowers initiate the vast majority of FCA cases, any restriction on their role could dramatically impact the government’s enforcement capabilities.

The expanded focus on customs enforcement represents a strategic pivot by the Department of Justice, targeting companies that potentially evade import duties or misrepresent country of origin information. This shift comes amid heightened attention to international trade compliance following recent tariff disputes and supply chain disruptions.

Similarly, the examination of DEI initiatives marks new territory for FCA enforcement. Companies that have received federal funding or contracts with diversity requirements may face scrutiny regarding the accuracy of their representations about compliance with these obligations.

For corporate compliance officers and legal departments, these developments signal the need for enhanced internal controls and thorough documentation practices across a wider range of business operations. Organizations receiving federal funds must ensure accurate reporting and strict adherence to program requirements to mitigate FCA exposure.

The record recoveries also reflect the government’s increased investment in enforcement resources and sophisticated data analytics to identify potential fraud patterns. This technological enhancement of investigative capabilities allows enforcement agencies to detect anomalies that might have previously gone unnoticed.

Industry observers note that the aggressive enforcement environment is unlikely to abate in the near term, given the substantial return on investment the government receives from FCA actions. For every dollar spent on FCA enforcement, the government typically recovers several times that amount.

As companies navigate this heightened enforcement landscape, legal experts recommend proactive compliance measures, including regular risk assessments, employee training, and robust internal reporting mechanisms. When potential issues arise, prompt investigation and, where appropriate, voluntary disclosure may help mitigate penalties.

The 2025 data confirms that the False Claims Act remains a cornerstone of the government’s fraud enforcement strategy, with its impact extending beyond financial recoveries to influence corporate behavior and compliance practices across industries that interact with federal programs.