On January 22, 2026, the Fraud Section of the U.S. Department of Justice’s (DOJ) Criminal Division published its Year in Review for 2025. The report summarizes activity across the Fraud Section’s Health Care Fraud (HCF), newly rebranded Market, Government, and Consumer Fraud (MGC), Foreign Corrupt Practices Act (FCPA), and newly formed Health and Safety (HSU) litigating units, and reveals an unmistakable focus on health care fraud enforcement.
Breaking Down the Fraud Section’s Data
Overall, the Fraud Section charged 265 individuals and secured 235 convictions, conducted 25 trials across 17 districts, and brought 15 corporate enforcement actions (12 resolutions and three indictments) that involved “total global monetary amounts” exceeding $1 billion.
- HCF. In 2025, the HCF Unit led all Fraud Section litigating units on nearly all key metrics, charging 194 and convicting 150 individuals, bringing four corporate enforcement actions (its first corporate criminal health care cases in nearly a decade, including two corporate indictments), and reporting $15.02 billion in alleged losses. The HCF Unit’s docket continues to reflect its data-driven and nationwide approach, highlighted by a record-setting National Health Care Fraud Takedown and the launch of the Health Care Fraud Data Fusion Center.
- MGC. The renamed and expanded successor to the Fraud Section’s Market Integrity and Major Frauds Unit charged 62 and convicted 75 individuals while bringing three corporate enforcement actions and entering into two Corporate Enforcement Policy (CEP) declinations, which involved the largest corporate monetary penalties ($694.5 million) imposed by any of the four litigating units in 2025.
- FCPA. Despite a brief pause in FCPA enforcement (discussed in previous Alston & Bird advisories here, here, and here), the FCPA Unit charged five and convicted six individuals, entered into one CEP declination, and brought two corporate enforcement actions, including a corporate indictment that marked the first such action in 15 years. These substantially lower FCPA enforcement totals are unsurprising in light of FCPA-related Executive Branch resource reallocation decisions and policy changes in 2025, but they also reflect the continued attention and resources devoted by the Fraud Section to FCPA enforcement.
- HSU. As the Fraud Section’s newest litigating unit, the HSU charged four and convicted four individuals while also bringing four corporate enforcement actions totaling $155.1 million. These corporate actions included violations of the Food, Drug, and Cosmetic Act and demonstrated the Fraud Section’s leveraging of criminal enforcement resources and responsibility acquired in 2025 from the since-shuttered DOJ Consumer Protection Branch.
A closer examination of the Fraud Section’s data reveals that nearly 85% of the more than $1.01 billion in total global monetary amounts reported in its corporate criminal enforcement matters is driven by two things: an agreement not to prosecute The Boeing Company and a DOJ Civil Division resolution with KBWB Operations LLC that pre-dated the HSU’s creation and does not appear to have involved the Fraud Section. Moreover, the total global monetary amounts imposed in FCPA- and MGC-related corporate criminal enforcement actions (excluding the Boeing resolution) are more than 80% below the next lowest annual total reported over the past five years.
Similarly, the number of trials and trial convictions reported by the Fraud Section are the lowest since the COVID period in 2020–2021, and the total number of individuals charged by the FCPA and MGC units are well below comparable five-year totals.
Health Care Fraud: An Unmistakable Priority
The HCF Unit’s results stand in stark contrast to the significant decline in non-HCF Fraud Section enforcement. The record enforcement activity reported by the HCF Unit reflects not only the growing use of data analytics and an aggressive investigative approach, but also the priority health care fraud continues to receive within the Criminal Division (see prior Alston & Bird advisory here). These results coincided with a similarly strong year in False Claims Act recoveries by the DOJ’s Civil Division, which were again driven in large part by enforcement in the health care and life sciences space (see recent Alston & Bird advisory here).
The DOJ also continues to encourage corporate whistleblowers across industries, using an expanding array of tools to incentivize reporting of corporate misconduct directly to enforcement authorities. This heightened government appetite and capability for health care and life sciences enforcement is a clear reminder of the importance of reevaluating and updating compliance programs and internal controls, as well as ensuring a prompt, appropriately tailored, and strategically sound response to potential violations.
Looking Ahead
Following a period of transition, the Fraud Section enters 2026 positioned to accelerate enforcement. The installation of permanent leadership, including a permanent chief, experienced deputy assistant attorney general, and Senate-confirmed assistant attorney general, replaces interim stewardship with a more stable reporting chain.
At the same time, the White House’s creation of a new DOJ Division for National Fraud Enforcement introduces another participant in the enforcement landscape. Even as structural questions remain about how this division will operate alongside existing fraud-focused components of the DOJ, its mandate to drive multi-district and multi-agency investigations expands the risk for companies and individuals. These developments are likely to further intensify health care fraud enforcement through 2026 and reinforce the importance of ensuring compliance programs and internal controls are fit for purpose.
If you have any questions, or would like additional information, please contact one of the attorneys on our White Collar, Government & Internal Investigations team.
You can subscribe to future advisories and other Alston & Bird publications by completing our publications subscription form.