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 April 30, 2026, the U.S. Department of Justice (“DOJ”) announced two significant developments that materially expand the federal government’s fraud enforcement footprint and reshape the landscape for potential targets and whistleblowers.  First, DOJ’s newly created National Fraud Enforcement Division (the “NFED”) (see our alert   here )  launched  the West Coast Health Care Fraud Strike Force (the “Strike Force”), a multi-district initiative covering Arizona, Nevada, and the Northern District of California.    Second, DOJ’s Civil Division  announced  the Fraud Oversight through Careful Use of Statistics (“FOCUS”)  initiative , which formalizes DOJ’s engagement with data miners filing qui tam complaints under the False Claims Act (“FCA”).    These actions signal an aggressive, data-driven, and resource-intensive approach to combating fraud against federal programs that entities and individuals should be prepared to navigate. NFED:...