Federal False Claims Act settlements · 2022 – August 2026
Every quarter we read the full federal settlement record and publish what we find — including the parts that cut against the headlines. This is the enforcement landscape as the data describes it, not as press releases describe it.
Finding 01 · Customs & tariff fraud
Customs fraud recoveries jumped from $102.3 million in 2025 to $583.5 million through August 2026 — a figure that looks like a step change. It is mostly one case. Perfectus Aluminum settled in May 2026 for $549.5 million over evaded antidumping and countervailing duties on Chinese aluminum extrusions. Strip that single case out and 2026 is running below 2025.
Case counts tell the plainer story: six, nine, four, seven, five. Volume has not moved in five years.
Customs fraud recoveries, 2022–2026
Dollars in millions. The 2026 bar is split to show the single case driving it.
Finding 02 · Pandemic relief
PPP settlements went from 10 in 2022 to 72 in 2025, with 51 already recorded through August 2026. They now account for 30.5% of all settlements but only 4.6% of dollars.
The more telling number is the median, which has risen roughly 26-fold in four years. The Justice Department has worked through the small, obvious cases and moved into substantive ones.
| PPP fraud | 2022 | 2023 | 2024 | 2025 | 2026 YTD |
|---|---|---|---|---|---|
| Settlements | 10 | 17 | 31 | 72 | 51 |
| Median settlement | $70,001 | $465,581 | $1,250,000 | $2,096,186 | $1,850,000 |
| Total recovered | $7.4M | $27.5M | $181.4M | $266.2M | $108.9M |
Finding 03 · Sector mix
Healthcare and pharmaceutical cases have run between 56% and 72% of recovered dollars every year since 2022. By case count the decline is clearer: 62.5% of settlements in 2022, 52.1% in 2026. The space is being taken by industrial goods, which went from $7.2 million in 2022 to $633.4 million in 2026 — almost entirely the customs cases above.
Settlements by fraud type, 2022–2026
Number of settlements per year. Cases carrying two codes appear under each.
Finding 04 · Distribution
Between 2022 and August 2026, the ten largest settlements produced 34.8% of all recovered dollars. The smallest half of all cases — 538 settlements — produced 2.4%. The median settlement is $2.3 million; the mean is $18.4 million.
The practical consequence is that year-over-year totals are close to meaningless. A headline that recoveries rose or fell by some percentage is usually a statement about whether one or two large pharmaceutical cases happened to close before December 31. We report medians and counts for that reason.
This is the most important thing to understand about enforcement data, and the reason we publish analysis rather than a table of cases.
A False Claims Act case takes years to surface. Conduct happens, an insider notices, a complaint is filed under seal, the government investigates while the case stays sealed, and a settlement follows. By the time a case appears in any settlement database, the underlying conduct is usually three to seven years old.
Anyone reading today's settlements is reading a description of the past. That is useful — it tells you what the government has proven it will pursue and pay for. It is not a forecast. When we describe something as an emerging area, we are drawing on filings, task force activity, and agency statements, and we say so.
Two cases in ten years
A genuinely new theory with almost no record behind it. The database holds two: GQG Partners ($500,000, September 2024) and IBM ($17.1 million, April 2026). Both were government-initiated rather than whistleblower-initiated. Commentary has run well ahead of the case law.
Two to eight cases a year
DOJ's Civil Cyber-Fraud Initiative has been widely predicted to produce a wave of cases. The settlement record does not show one yet: between two and eight settlements a year since 2022, peaking at $185.4 million in 2024. Worth watching, not yet worth calling a trend.
Read this before citing anything above
If you are seeing something
Every settlement above began with someone inside an organization who saw a pattern and decided it mattered. If you are weighing whether what you are seeing is worth reporting, that conversation is confidential and costs nothing.
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