As procurement fraud enforcement continues to be a priority for the Department of Justice and other federal agencies, we take a look back at significant 2025 enforcement developments affecting government contractors, grant recipients and participants in federal programs in our 2025 Procurement Fraud Review.

The Review examines notable False Claims Act settlements, procurement fraud investigations, cybersecurity enforcement developments, customs and tariff-related matters, and other key trends shaping the government contracting landscape. Many of the enforcement themes that emerged in 2025 — including defective pricing, cybersecurity compliance obligations, tariff evasion and pandemic relief fraud — continue to receive significant government attention in 2026.

The Department of Justice reported that settlements and judgments under the False Claims Act exceeded $6.8 billion in fiscal year 2025, the highest annual recovery total in the statute’s history. Although healthcare matters continued to account for most FCA recoveries, DOJ also pursued significant procurement-related matters involving defense contracts, cost mischarging, customs fraud and cybersecurity compliance.

Together, these matters reflect the government’s continued focus on procurement integrity, contractor compliance obligations and fraud affecting federal funding programs.

Download the 2025 Procurement Fraud Review.

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Photo of Richard Arnholt Richard Arnholt

Richard Arnholt advises companies, large and small, on the complex rules and regulations applicable to grants and contracts from federal and state governmental entities. In an era of increased budgetary pressures for contractors, Richard focuses his practice on providing practical business and legal…

Richard Arnholt advises companies, large and small, on the complex rules and regulations applicable to grants and contracts from federal and state governmental entities. In an era of increased budgetary pressures for contractors, Richard focuses his practice on providing practical business and legal guidance to help clients efficiently navigate the minefield of government procurement and grant regulations.

Photo of Denise Barnes Denise Barnes

Denise Barnes counsels clients in high-stakes matters related to fraud allegations, including in healthcare, federal contract procurement, and securities and financial services. A former trial attorney with the U.S. Department of Justice (DOJ), she has extensive experience handling issues related to compliance, white-collar…

Denise Barnes counsels clients in high-stakes matters related to fraud allegations, including in healthcare, federal contract procurement, and securities and financial services. A former trial attorney with the U.S. Department of Justice (DOJ), she has extensive experience handling issues related to compliance, white-collar and regulatory investigations, and complex commercial litigation. Denise represents businesses in public and non-public investigations, regulatory inquiries, and proceedings involving federal and state agencies. She frequently assists clients navigating government investigations related to allegations arising under the False Claims Act (FCA), Anti-Kickback Statute (AKS), Stark Law, and Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA). Notably, during her tenure at the DOJ, she spearheaded numerous multi-district investigations that resulted in over $2.7 billion in recoveries for federal taxpayers.

Photo of Scott Gallisdorfer Scott Gallisdorfer

Scott Gallisdorfer focuses his practice on complex litigation and government and internal investigations, with an emphasis on matters related to the healthcare industry. Scott has significant experience in False Claims Act (FCA) litigation and healthcare fraud and abuse investigations, including civil and criminal…

Scott Gallisdorfer focuses his practice on complex litigation and government and internal investigations, with an emphasis on matters related to the healthcare industry. Scott has significant experience in False Claims Act (FCA) litigation and healthcare fraud and abuse investigations, including civil and criminal investigations by the U.S. Department of Justice (DOJ), U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG), and other federal and state regulators.

Photo of Todd Overman Todd Overman

Todd Overman is the chair of the firm’s Government Contracts practice and Managing Partner of the Washington, D.C. office.  He has over twenty years of experience advising companies on the unique aspects of doing business with the federal government. Over the last decade…

Todd Overman is the chair of the firm’s Government Contracts practice and Managing Partner of the Washington, D.C. office.  He has over twenty years of experience advising companies on the unique aspects of doing business with the federal government. Over the last decade, he has advised on more than 50 transactions involving the purchase or sale of a government contractor.