In January 2026, the DOJ Criminal Division’s Fraud Section published its Year in Review for 2025. The stats are dramatic. More than 250 individuals were charged, roughly two dozen trials held across 17 districts, and 15 corporate enforcement actions spanning procurement fraud, healthcare fraud, trade and customs misconduct, and securities cases. The sums involved reached over $1 billion.
The numbers show the DOJ’s first full year under Attorney General Pam Bondi is actively litigating corporate fraud cases. Trial activity at that scale signals confidence in investigative quality and a willingness to test cases before juries. Corporate indictments, which had been relatively rare in prior years, also featured heavily. That shifts the risk calculus for boards and general counsel. Deferred prosecution agreements remain part of the landscape, yet the comfort that every matter will resolve through negotiation has weakened.
The Year in Review also emphasises the growing use of proactive data analysis. The Fraud Section’s model means prosecutors are identifying anomalies in claims, billing patterns, tariff classifications, or securities data. Whistleblowers are then adding more colour and context to the narrative.
The creation of a National Fraud Enforcement Division
The Year in Review was followed by the White House announcement of a new Division for National Fraud Enforcement. The stated ambition is centralisation: a nationwide criminal and civil fraud enforcement body, led by a Senate-confirmed Assistant Attorney General, with authority to coordinate multi-district and multi-agency investigations.
At a minimum, this reflects a political and institutional decision to elevate fraud affecting federal programs, federally funded benefits, and government spending streams. This represents a significant increase in fraud enforcement. Matters that might previously have been handled in a single district could now attract central scrutiny, harmonised expectations, and parallel civil and criminal exposure.
The US Treasury’s parallel initiatives, including FinCEN activity tied to alleged benefits fraud in Minnesota, reinforce that this is not simply a Criminal Division project. Fraud enforcement is being paired with financial intelligence tools and targeted reporting mechanisms. Where federal funds are involved, enforcement is actively increasing.
Federal money is once again the organising principle
Taken together, these announcements make it clear that fraud touching public funds sits at the centre of the DOJ’s white-collar agenda. The 2025 portfolio highlights procurement and grant fraud, misuse of relief funds, trade and tariff evasion, healthcare program fraud, and market manipulation. Each of those categories shares a common feature. They involve representations to, or financial flows from, the federal government.
For corporations, the exposure is in federal funds. Certifications in government contracts. Customs classifications. Reimbursement submissions. Eligibility attestations. Data integrity in grant-funded programs. The risk does not arise only from deliberate misconduct. It can arise from weak documentation, informal override practices, or poorly governed third parties operating at the edge of federal programs.
Nonprofits and educational institutions administering federally funded initiatives sit in the same frame. So do fintech and payments businesses that facilitate the distribution of public benefits. Fraud risk, in the DOJ’s current articulation, is not confined to traditional defence contractors or healthcare giants.
Data-led enforcement changes the compliance baseline
The Fraud Section’s emphasis on analytics deserves particular attention. When prosecutors describe proactive data mining to identify outlier patterns, they are signalling that statistical anomalies can become investigative triggers.
Compliance programs that rely on policy statements and reactive investigations will look thin in that environment. The question prosecutors increasingly ask is whether a company uses its own data in a disciplined way. Can it detect abnormal billing spikes, unusual discount structures, routing anomalies in trade flows, or repeated certification changes? Can it demonstrate that it tests controls rather than assuming they operate?
The DOJ’s Evaluation of Corporate Compliance Programs framework already expects continuous improvement and testing. The Fraud Section’s 2025 narrative adds operational weight to that expectation. Analytics is no longer a sophistication marker. It is becoming table stakes.
Division for National Fraud Enforcement and the False Claims Act: Increasing corporate liability
The new Division for National Fraud Enforcement will concentrate priority-setting and oversight at a higher level, even if much of the day-to-day investigative work remains with US Attorneys’ Offices and established DOJ components.
A centrally coordinated fraud investigation may carry different settlement dynamics, closer review of proposed resolutions, and a greater likelihood of parallel civil and criminal tracks. This is particularly relevant when federal funds are involved, because the False Claims Act continues to function as one of the government’s most powerful civil enforcement tools.
Aggressive False Claims Act enforcement remains a priority. In practice, that means procurement fraud, grant compliance failures, healthcare reimbursement issues, customs representations, and certifications tied to federal programs can migrate quickly into FCA territory, with treble damages and much stronger statutory penalties.
The Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy remains the core criminal framework. Yet the institutional backdrop has shifted toward greater coordination, heightened scrutiny of matters affecting public funds, and stronger integration between criminal prosecutors and civil FCA teams. A disclosure strategy that looks narrowly at criminal risk without modelling parallel False Claims Act exposure is unlikely to be sufficient.
In that context, early decisions around self-disclosure, internal investigation scope, and engagement strategy require sharper discipline. Internal reviews need to test not only intent and control design, but also the accuracy of claims submitted to the government and the evidentiary basis for certifications.
What a credible response looks like
A compliance program aligned with this enforcement climate begins with clarity about federal exposure. Organisations should be able to map where they receive, administer, or certify against federal funds and where they interact with customs authorities, reimbursement systems, or regulated financial flows. Ownership of those touchpoints should be explicit.
Policies governing government submissions need to be treated with the same rigour as financial reporting controls. That means documented review chains, version control, and a clear evidentiary basis for certifications. Informal workarounds or undocumented judgment calls are precisely the kinds of weaknesses prosecutors can reframe as recklessness.
Internal monitoring should be capable of identifying anomalies that mirror the government’s own analytical tools. Transaction testing, targeted audits of high-risk programs, and review of third-party intermediaries are practical expressions of that expectation.
For financial institutions and payments firms, the line between fraud compliance and AML compliance is increasingly thin. FinCEN’s use of geographic targeting orders in response to alleged benefits fraud demonstrates how quickly reporting obligations can tighten in specific regions or sectors. Monitoring scenarios, escalation criteria, and suspicious activity reporting practices need to reflect red flags associated with public-benefits fraud and cross-border transfers.
