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This past year, the False Claims Act (FCA) continued to be a key tool for the Justice Department and whistleblowers to bring suits against companies, including those in the financial services sector. With over $6.8 billion in FCA recoveries this year, the highest mark yet, more cases were filed this year than ever before. Despite this increase and the corresponding increase in cases filed by relators, the total share of relators' awards went down and 75% of the total FCA qui tam recoveries were from suits where the DOJ intervened. Overall, intervened cases accounted for more than 10 times the amount of recoveries than non-intervened cases. The government continued to make clear that cybersecurity was an area of focus and began an initiative to investigate companies with government contracts that have "illegal DEI" initiatives. As always, companies in the financial services sector must remain vigilant and take the necessary steps to prevent FCA violations. 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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