Year-End False Claims Act Roundup: Key Cases, Enforcement Trends, and What Businesses Should Do Now
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...