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ARTICLE · 12 MARCH 2025

False Claims Act In 2025: Looking Back And What's Ahead

Foley Hoag LLP
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This is the sixth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments...

United StatesCriminal Law
Foley Hoag LLP
Foley Hoag LLP
Caroline Donovan
Caroline Donovan
David Lazarus
David Lazarus
Yoni Bard
Yoni Bard
Rachel Kerner
Rachel Kerner
Caroline Holliday
Caroline Holliday
Shayonna Cato
Shayonna Cato
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This is the sixth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several weeks. Our previous post, "Year in Preview: Review of and Insights into Investigations by the 119th Congress" can be found here.

The Attorney General and key Department of Justice leadership are now in place and appear to have hit the ground running. As the new administration looks to deploy the False Claims Act (FCA) aggressively and in new ways, we consider below what these changes portend. First, to the extent that past may be prologue, we provide a comparative analysis of FCA enforcement under President Trump's first term and President Biden's term. Second, we consider both historically important priorities for enforcement and areas that have become significant in the early days of the second Trump administration. We conclude with a review of

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