On January 22, 2026, the Department of Justice (DOJ or the Department) Criminal Fraud Section issued its 2025 Year in Review summary (YIR Summary). Our more detailed analysis of the full YIR Summary can be found here. DOJ’s Health Care Fraud Unit (the HCF Unit) is focused on “prosecuting complex health care fraud matters and cases involving the illegal prescription, distribution, and diversion of controlled substances.” To carry out its mission, in 2025, the HCF Unit operated 8 Health Care Fraud Strike Forces in 26 federal judicial districts across the nation. The HCF Unit’s reported average return on investment is $106.76 per $1 spent. 

The Department of Justice's (DOJ or the Department) Criminal Fraud Section has undergone its most significant reorganization in years, according to its recently released 2025 Year in Review. Those changes and the current climate of enforcement uncertainty require more vigilance, not less, from corporate compliance and law departments.

Learn how DOJ’s expanded Voluntary Self-Disclosure policy and evolving use of NPAs and DPAs create new opportunities for health care companies to resolve enforcement actions. Explore strategies for cooperation, remediation, and compliance.

On June 23, 2025, the United States Court of Appeals for the Ninth Circuit affirmed a district court judgment in a case in which the jury found the defendant knowingly made false statements on customs forms to avoid paying duties on Chinese imports. The decision affirms an expansive application of the False Claims Act (“FCA”) that plays directly into the hands of the Trump administration’s evolving enforcement priorities.

The first 120 days of the Trump administration have been characterized by dramatic changes in the realm of white-collar enforcement. Recently issued memoranda and policy guidance from DOJ contains critical details regarding the new administration’s enforcement priorities.  

Our 2025 edition of EnforceMintz reflects on health care enforcement trends, predicts how health care enforcement may evolve, and offers practical guidance about what these trends and predictions mean for health care providers, payors, and other stakeholders.

Over the past two years, the Department of Justice has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. This article explores the DOJ’s new policies, the benefits of self-disclosure, and the challenges companies face in complying with these initiatives.

In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to create a new whistleblower rewards pilot program.