False Claims Act Playbook

On February 24, 2026, the U.S. Department of Justice (DOJ) and the U.S. Department of Homeland Security (DHS) jointly announced that the U.S. Attorney’s Office in Chicago would be a lead prosecutorial partner on the recently launched interagency Trade Fraud Task Force. Originally launched on August 29, 2025, the Trade Fraud Task Force aims to aggressively pursue importers, purchasers, supply chain actors, and other entities engaged in customs fraud, including duty evasion, misclassification of goods, and smuggling of prohibited items. In this article, we evaluate DOJ’s continued commitment to designate substantial resources to its initiative to combat customs and trade fraud.

On October 22, 2024, the Department of Justice announced a False Claims Act (FCA) settlement related to a government contractor’s failure to adhere to certain cybersecurity requirements. Specifically, Pennsylvania State University (Penn State) has agreed to pay US$1.25M to resolve allegations that it violated the FCA by failing to comply with cybersecurity requirements in fifteen contracts or subcontracts involving the Department of Defense (DOD) or the National Aeronautics and Space Administration (NASA). The DOJ announcement is available here: https://www.justice.gov/opa/pr/pennsylvania-state-university-agrees-pay-125m-resolve-false-claims-act-allegations-relating.