In an August 13 memorandum, the Department of Justice laid out the enforcement priorities for its National Fraud Enforcement Division, setting forth the five top areas of focus. The Trump administration created the Fraud Division earlier this year to lead the effort to combat fraud in government procurement and programs, as well as in financial markets. The recent memo announced that the Fraud Division will prioritize enforcement of fraud involving: (1) public trust and financial integrity, (2) healthcare, (3) internal revenue, (4) global trade and commerce, and (5) corporate misconduct.
Public trust and financial integrity
The Fraud Division’s memorandum describes procurement fraud as a “critical priority,” explaining that defective pricing, bid rigging, bribery, product substitution and billing frauds reduce the quality of services the government provides, undermine trust in public programs, and threaten national security and military preparedness. In addition, fraud in government benefit programs that support the country’s most vulnerable citizens not only harms individuals but undermines trust in public assistance programs.
Healthcare
Noting that government healthcare spending is expected to grow from $3 trillion a year to over $7 trillion a year, and that an estimated 3-10 percent of that is lost to fraud, the memorandum describes efforts to combat fraud in healthcare programs. Those efforts include using “cutting-edge” data analysis to combat complex schemes involving telemedicine programs, home healthcare and hospice schemes, and deceptive marketing of unsafe medical products and services.
Internal Revenue
Tax fraud remains a priority for DOJ, which will continue to coordinate across agencies to deploy tax tools, data analytics, financial forensics, and nationwide coordination to fight tax evasion. Noting that those who defraud government programs often also simultaneously violate the internal revenue laws, the Fraud Division plans to emphasize fostering intra-division and interagency coordination.
Global Trade and Commerce
Trade laws will remain a top priority for the Fraud Division and the cross-agency Trade Fraud Task Force will continue to play a role. The Division will prioritize “systemic, high-impact noncompliance”, which includes focusing on transshipment fraud, country-of-origin misrepresentation, undervaluation of imported goods to avoid customs duties, sanctions evasion, and foreign forced labor schemes.
Corporate Misconduct
Finally, the memorandum states that the Fraud Division will continue the department’s longstanding emphasis on prosecuting corporate misconduct. The Division plans to work closely with the Corporate Enforcement Section to hold organizations accountable when they violate the law but also reward organizations that voluntarily self-disclose and cooperate in investigations.
The Role of Whistleblowers in Combating Fraud
The number one tool the government has to fight fraud is whistleblowers. The False Claims Act empowers whistleblowers to bring lawsuits to redress fraud against the government and entitles them to an award if the lawsuit succeeds. Other whistleblower programs, such as the SEC and CFTC whistleblower programs, reward whistleblowers who report financial frauds if their tips result in successful enforcement by the government.
Whistleblowers play an integral role in exposing fraud that is especially hard to detect. And whistleblowers often bring something that data analysis typically lacks – evidence that misconduct was done with knowledge that it was wrong and was not merely accidental or negligent.
In the fiscal year ending September 30, 2025, settlements and judgments under the False Claims Act exceeded $6.8 billion, the highest in a single year in the history of the False Claims Act. According to DOJ, whistleblowers were responsible for over $5.3 billion, accounting for nearly 80 percent of the federal False Claims Act recoveries. In fiscal year 2025, whistleblowers filed 1,297 False Claims Act lawsuits, the highest number in a single year.
The SEC and CFTC whistleblower programs have also led to important enforcement actions to protect investors and financial markets. For example, in FY 2025, the SEC awarded a total of more than $60 million to 48 individual whistleblowers and made 82 preliminary award determinations recommending awards. The substantial award amount indicates the financial impact of SEC whistleblowers, as awards under that program are 10-30% of the government’s recovery.
Fraud against the government threatens harm not only to the Treasury, but also to patients, the military, and people and organizations that government programs are intended to help. Financial fraud harms investors directly and undermines public trust in the market.
The private-public partnership between the government and whistleblowers has been highly effective, not only at redressing fraud but also at serving to deter future misconduct. Whistleblowers will continue to be at the forefront of the government’s efforts to combat fraud.
Phillips & Cohen is the nation’s most successful law firm representing whistleblowers. The firm’s cases have helped recover more than $13 billion in civil settlements and criminal fines. Phillips & Cohen represents whistleblowers in qui tam lawsuits as well as whistleblower claims under other reward programs, including the SEC, CFTC, and IRS whistleblower programs. If you know of fraud against the government or financial markets and would like to speak to an experienced whistleblower attorney, contact Phillips & Cohen for a confidential review of your case.