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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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