Welcome to Fraud by the Numbers
Welcome to The Anti-Fraud Coalition’s Sixth Annual Fraud by the Numbers! Each year in September, TAF Coalition uses cold, hard numbers and facts to illustrate how fraud costs the government, taxpayers, and financial market participants – and how impactful whistleblowers can be in stopping that fraud. We will post blogs throughout the month of September demonstrating what the numbers teach us about fraud and how enforcement is aided by whistleblowers. Let’s review what fraud enforcement has looked like in the past year.
FCA Enforcement: Record Recoveries and New Enforcement Priorities
Fiscal year 2025 was a record-breaking year across the board for False Claims Act. The U.S. Department of Justice (DOJ) released its FCA data for fiscal year (FY) 2025 in January, and reported settlements and judgments of more than $6.8 billion, the highest recovery in a single year in the history of the FCA. Whistleblower suits also broke records, with 1,297 new qui tam complaints filed. That’s a blockbuster year for the FCA (though some of those amounts are pending on appeal)! We love to see it, as the FCA continues to be the government’s number one tool for stopping fraud and recovering stolen taxpayer dollars, and whistleblowers initiating those cases continues to be critical to the government’s ultimate recovery.
The FCA is also a key component in the Trump administration’s high-profile initiatives to fight fraud—such as the creation of the Presidential Task Force to Eliminate Fraud and the Department of Justice’s National Fraud Enforcement Division. One strategy focuses aggressively on root-and-branch enforcement across safety-net programs like Medicaid, SNAP, and Medicare, alongside crackdowns on elder scams and pandemic relief exploitation. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) have withheld or deferred over $2.7 billion in federal Medicaid matching funds across multiple enforcement actions, citing fraud, waste, and documentation deficiencies.
The Trump administration has also been pursuing FCA enforcement in areas beyond the decades-old fight against healthcare fraud. For instance, the Trade Fraud Task Force has touted over $1 billion in civil and criminal recoveries from increased customs and tariffs enforcement. DOJ is also using the FCA through its Civil Rights Fraud Initiative. In the first case under that initiative, IBM agreed to pay $17 million to resolve allegations that it falsely certified compliance with anti-discrimination clauses in its federal contracts while maintaining certain DEI employment practices.
While there is clearly appetite for fraud enforcement at the federal level, resources to prosecute those cases continues to be scarce, highlighting the need for whistleblowers and the lawyers representing them to supplement the government’s ability to prosecute fraud. State Attorneys General are also dedicating more resources to fighting fraud on programs like Medicaid and are increasingly using their own state FCAs to fight fraud on the states.
Antitrust Whistleblower Program
Antitrust enforcement is another priority where whistleblowers play a critical role. Only 6 months after the Antitrust Whistleblower program was created, DOJ and the Postal Service made the program’s first award to a whistleblower who exposed a price fixing scheme involving used cars. The award illustrates how whistleblowers can support the administration’s “America First Antitrust” initiative targeting conduct that inflates everyday consumer costs or suppresses competition.
Dodd-Frank Whistleblower Programs
Enforcement under the SEC and CFTC whistleblower programs remains anemic compared to years past. In FY2026 the SEC did issue $28 million more in whistleblower awards than the year prior (FY2026 recoveries totaled $88 million compared with $60 million in FY2025). However, nearly 90% of the FY2026 total went to just three individuals, and it is hundreds of millions of dollars less than in years past.
Over at the CFTC there have only been 2 awards this fiscal year, totaling roughly $10 million.
What to Look Forward to In This Year’s Fraud by the Numbers Series
Enforcement under the SEC and CFTC whistleblower programs remains anemic compared to years past. In FY2026 the SEC did issue $28 million more in whistleblower awards than the year prior (FY2026 recoveries totaled $88 million compared with $60 million in FY2025). However, nearly 90% of the FY2026 total went to just three individuals, and it is hundreds of millions of dollars less than in years past.
Over at the CFTC there have only been 2 awards this fiscal year, totaling roughly $10 million.
What to Look Forward to In This Year’s Fraud by the Numbers Series
We are excited to once again present you with facts and figures related to fraud across programs and industries. Our members will dig in to state FCAs and Medicaid fraud and take a look at what is happening in whistleblower programs abroad. We will also focus on various hot topics in healthcare fraud, such as nursing home fraud and Medicare Advantage. We will also take a deeper dive into last year’s numbers at the Dodd-Frank programs, and take a closer look at new programs, such as the Antitrust Program and the Corporate Whistleblower Awards Program. We will also explore newer areas of heightened enforcement, such as data-driven cases, prediction markets, and customs.
Fraud by the Numbers is a massive undertaking each year, and we’d like to thank all of our contributors for their time researching, writing, and editing to make this year’s series a success:
• The Anti-Fraud Coalition staff in addition to myself: Grace Swindler (Director of Legal Education) and Devan Eaton (Public Interest Advocacy Fellow)
• The Anti-Fraud Coalition Members: Kate Scanlan (Keller Grover), Nick Mendoza (Murphy Anderson), Max Voldman (Whistleblower Partners), Christina Milnor (Milnor Law PLLC), Thomas Elrod (Kirby McInerney), Kathleen Gallagher (Gallagher & Lipshutz), Jagir Patel (Phillips & Cohen), Tony Munter (Price Benowitz LLP), Gia Grimm (Joseph Greenwald Laake), Erica Roberts (Sanford Heisler Sharp McKnight), Mary Inman (Whistleblower Partners), and Liz Soltan (Whistleblower Partners) for their contributions in writing and editing many of the posts in this project.
Jacklyn DeMar is the President & CEO of The Anti-Fraud Coalition
