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U.S. Justice Department Intensifies False Claims Act Enforcement Focus, Former DOJ Officials Announce Upcoming Analysis

Former Department of Justice officials Zach Terwilliger and Alexander Canizares are set to deliver a comprehensive analysis of the DOJ’s evolving corporate enforcement priorities, with particular emphasis on False Claims Act litigation and fraud allegations. The presentation, scheduled for November 4, 2025, aims to provide critical insights for companies navigating increasingly complex federal regulatory enforcement.

The session will decode recent DOJ policy pronouncements related to the False Claims Act, which has become one of the government’s most powerful tools for combating fraud against federal programs. Drawing on their insider experience at the Justice Department, the two attorneys will examine recent cases that exemplify the current administration’s enforcement approach and strategic priorities.

Notably, the presentation will highlight emerging enforcement risks in three key areas that have gained significant regulatory attention: Diversity, Equity, and Inclusion (DEI) initiatives; tariff compliance; and cybersecurity practices. These areas represent new frontiers in False Claims Act enforcement for government contractors and other businesses that interact with federal agencies.

The DEI component reflects growing scrutiny of companies that make representations about their diversity practices in government contracts or federal submissions. As organizations increasingly tout their DEI commitments to secure government business, federal prosecutors have begun examining whether these claims are substantive or merely performative, potentially opening the door to misrepresentation claims.

On the tariff front, the enforcement landscape has grown increasingly complex amid ongoing trade tensions and changing import regulations. Companies that improperly classify imports or misrepresent country of origin information to avoid tariffs face potential FCA liability, with several high-profile cases already demonstrating the government’s willingness to pursue such matters aggressively.

Cybersecurity compliance represents perhaps the most technically complex area of emerging FCA risk. Government contractors that certify compliance with federal cybersecurity standards but fail to maintain adequate protections have faced growing liability under the FCA, particularly following several high-profile breaches affecting federal information systems.

The presentation will also cover practical strategies for corporate compliance officers and legal teams to manage potential whistleblower situations. The FCA’s qui tam provisions, which allow private individuals to file lawsuits on behalf of the government and receive a portion of any recovery, have made whistleblower claims a significant source of enforcement actions. Terwilliger and Canizares plan to outline best practices for addressing internal concerns before they escalate to formal complaints.

For companies already facing qui tam litigation or DOJ investigations, the former Justice Department attorneys will provide insights into developing effective defense strategies based on their experience from inside the enforcement apparatus. Their perspective includes understanding how prosecutors evaluate potential cases, what factors influence settlement decisions, and how to navigate the complex procedural aspects of FCA litigation.

This analysis comes at a crucial time for the business community, as FCA enforcement has seen record settlements in recent years. In fiscal year 2023 alone, the Justice Department recovered over $5.6 billion from FCA cases, continuing a trend of aggressive enforcement that has spanned multiple administrations.

The virtual session, scheduled to run from 12:00 PM to 1:00 PM Central Time, reflects the growing importance of proactive compliance strategies in areas where government enforcement priorities are evolving rapidly. For businesses that contract with the federal government or participate in federally funded programs, understanding these enforcement trends has become essential to managing legal and financial risk.

Companies interested in participating in the November 2025 session are encouraged to register in advance, as the specialized nature of the presentation and the speakers’ backgrounds are likely to draw significant interest from compliance professionals, in-house counsel, and executives across industries that interact with federal agencies.

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10 Comments

  1. Interesting that the webinar will highlight emerging risks in areas like DEI initiatives and cybersecurity. Those seem like growing focus areas for regulators. It will be helpful to understand the DOJ’s enforcement approach in those domains.

    • I wonder if the presenters will touch on best practices for companies to demonstrate compliance and mitigate False Claims Act exposure in those newer risk areas.

  2. The False Claims Act is a powerful tool the government uses to combat fraud, so it’s critical for companies to stay on top of the latest enforcement trends. Analyzing recent cases and policy changes will provide valuable insights.

    • Elijah Jackson on

      I’m glad the presenters have DOJ experience to share their insider perspective. That should make for a really informative session.

  3. Oliver Johnson on

    The False Claims Act has become one of the government’s most powerful tools for combating fraud. Hearing from former DOJ officials on the latest enforcement trends and risks will provide valuable insights for companies.

  4. Isabella Moore on

    This webinar sounds like an important deep dive into the evolving False Claims Act enforcement landscape. I’m curious to learn more about the DOJ’s strategic priorities and emerging risk areas like DEI initiatives and cybersecurity practices.

    • Michael Williams on

      Do you think the webinar will address how companies can proactively strengthen their compliance programs to mitigate these enforcement risks?

  5. With the DOJ’s increased scrutiny on fraud allegations, this webinar is well-timed. Learning about the evolving enforcement priorities and strategies will be crucial for companies to stay compliant.

  6. This webinar sounds like a must-attend for companies navigating the complex federal regulatory enforcement landscape. The DOJ’s insider perspective on False Claims Act litigation and fraud allegations will be extremely valuable.

  7. Amelia Z. White on

    It’s smart for the presenters to cover emerging enforcement risks in areas like DEI initiatives and cybersecurity. Those seem to be growing focus areas for regulators, so understanding the DOJ’s approach will be very relevant.

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