Compliance Stuff

DOJ’s Civil Division recently issued a memorandum prioritizing the expedited review of whistleblower-initiated False Claims Act (“FCA”) complaints targeting alleged fraud in state-administered programs receiving federal funding. This reform is designed to expedite FCA “meritorious qui tam cases, maximize finite enforcement resources, and focus on dismantling sophisticated fraud schemes that exploit taxpayer-funded programs,” including housing, food, medical care, and cash assistance.  The new policy signals materially shorter response timelines, increased likelihood of parallel civil and criminal scrutiny, and heightened enforcement risks. Background and Policy Context President Trump’s Executive Order , Establishing the Task Force to Eliminate Fraud, directed DOJ to promote meritorious qui tams and ensure their prompt review. The policy also aligns with DOJ’s broader efforts to enhance enforcement efficiency, including the launch of the National Fraud Enforcement Division (see ...

On February 13, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) launched a  new webpage  to confidentially accept whistleblower tips on fraud, money laundering, and sanctions violations. This Q&A with Jane Norberg, co-chair of Ogletree Deakins’ Whistleblower and Compliance practice group, is designed to help employers understand the legal considerations and whistleblower protections. 00:00 24:53 Quick Hits FinCEN has launched a confidential webpage for reporting tips on fraud, money laundering, and sanctions violations, enhancing support for whistleblowers . Whistleblowers reporting violations to FinCEN are protected from retaliation by their employers and may receive rewards ranging from 10 percent to 30 percent of monetary sanctions that exceed $1 million , once new regulations are finalized. Q: What types of whistleblower tips are considered under this new website? A:   FinCEN’s Office of the Whistleblower accepts tips rela...

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. Case Law Update: Constitutional Challenges and Qui Tam Relators In 2025, the constitutionality of the FCA’s qui tam provisions—which empower private litigants (relators) to prosecute fraud claims on the government’s behalf—continued to emerge as a focal point of judicial debate . Historically, federal courts, including the U.S. Court of Appeals for the Fifth, Sixth, Ninth, and Tenth Circuits, have rejected arguments ch...

 On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy, and added new priority areas to the Corporate Whistleblower Awards Pilot Program Policy . The DOJ also introduced a new corporate monitor selection policy. Below, we highlight what to know about the new White Collar Enforcement Plan and the revised Corporate Whistleblower Awards Pilot Program Policy and what actions you can take today.  Below, we highlight what to know about the new White Collar Enforcement Plan and the revised Corporate Whistleblower Awards Pilot Program Policy and what actions you can take today. What to Know The plan underscores the US government’s “America First” priorities. Foreign organizations may be at increased enforcement risk. The DOJ is committed to investigating and prosecuting bribery, despite the temporary Foreign Corrupt ...