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As in years past, the government continued to pursue False Claims Act (FCA) investigations and lawsuits against contractors in 2025. With over $6.8 billion in recoveries in 2025 and an increased number of cases filed, 2025 also saw the creation of a cross-agency Trade Fraud Task Force to begin instituting FCA actions as a customs enforcement tool in addition to duty and penalty collection actions under the Tariff Act of 1930. In announcing the Trade Fraud Task Force, the DOJ noted that the DOJ’s Commercial Litigation Branch had “reached civil settlements to resolve allegations of improperly evaded customs duties across a wide range of products, including multi-layer wood flooring, plastic resin, extruded aluminum products, and quartz surface products.” Further, in December, the DOJ announced a significant FCA settlement under which the defendant agreed to pay $54.4 million to settle FCA allegations that it failed to pay duties owned on tungsten carbide products imported from the People’s Republic of China. The DOJ has reiterated focus on this enforcement area moving into 2026. To keep you apprised of the current enforcement trends and the status of the law, Bradley’s Government Enforcement and Investigations Practice Group is pleased to present the False Claims Act: 2025 Year in Review, our 14th annual review of significant FCA cases, developments, and trends.

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Photo of Ty E. Howard Ty E. Howard

Ty Howard brings the perspective of a former state and federal prosecutor to defending and counseling businesses and individuals involved in government investigations, compliance matters, False Claims Act and whistleblower cases, related business litigation, and white-collar criminal matters. As a litigator and chair…

Ty Howard brings the perspective of a former state and federal prosecutor to defending and counseling businesses and individuals involved in government investigations, compliance matters, False Claims Act and whistleblower cases, related business litigation, and white-collar criminal matters. As a litigator and chair of Bradley’s Government Enforcement and Investigations group, he works collaboratively with clients, across many industries, to find creative solutions to their compliance needs, to conduct sensitive investigations and negotiations, and—when necessary—to mount a vigorous defense.

Photo of Brad Robertson Brad Robertson

Brad Robertson works with clients facing government investigations and litigations, dealing with whistleblower allegations and qui tam actions, and planning compliance programs to prevent these occurrences in the first place. He helps his clients navigate compliance and potential liability under the False Claims…

Brad Robertson works with clients facing government investigations and litigations, dealing with whistleblower allegations and qui tam actions, and planning compliance programs to prevent these occurrences in the first place. He helps his clients navigate compliance and potential liability under the False Claims Act, Anti-Kickback Statute and FIRREA, in addition to other areas of healthcare fraud and abuse, financial/mortgage fraud, and white collar criminal law.

Photo of Jonathan H. Ferry Jonathan H. Ferry

Jon Ferry brings his substantial experience as a federal prosecutor to assisting clients in False Claims Act litigation, government investigations and other enforcement actions, internal risk analysis and internal investigations.

Jon served as Assistant U.S. Attorney for the Western District of North Carolina…

Jon Ferry brings his substantial experience as a federal prosecutor to assisting clients in False Claims Act litigation, government investigations and other enforcement actions, internal risk analysis and internal investigations.

Jon served as Assistant U.S. Attorney for the Western District of North Carolina for over seven years. As the head of the Affirmative Civil Enforcement (ACE) program and the Healthcare Fraud Coordinator for the U.S. Attorney’s Office, Jon led and supervised numerous investigations in the areas of healthcare, financial services and other complex frauds. He has significant experience with the False Claims Act and other whistleblower actions, healthcare regulations (including the Anti-Kickback Statute and Stark Law), the Food Drugs and Cosmetics Act, and the Financial Institutions Reform, Recovery and Enforcement Act (FIRREA).

Photo of Alexis D. Gregorian Alexis D. Gregorian

Alexis Gregorian is a partner in the firm’s Government Enforcement & Investigations Practice Group. She is a former federal prosecutor and seasoned trial lawyer with extensive experience in complex fraud, health care, and government investigations. Her practice focuses on representing companies and individuals…

Alexis Gregorian is a partner in the firm’s Government Enforcement & Investigations Practice Group. She is a former federal prosecutor and seasoned trial lawyer with extensive experience in complex fraud, health care, and government investigations. Her practice focuses on representing companies and individuals in government investigations, sensitive internal investigations, litigation, and other significant business and legal matters.