Executive summary

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Executive summary

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With every new administration comes uncertainty, and that was perhaps never truer than in 2025. But as the dust settles on the first year of Trump’s second term, we are beginning to see a clearer picture of what FCA enforcement will look like going forward – and can prepare accordingly.

A new approach: Targeting “illegal DEI” with the FCA

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A new approach: Targeting “illegal DEI” with the FCA

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The Trump Administration’s FCA enforcement priorities

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The Trump Administration’s FCA enforcement priorities

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Tariff enforcement meets the FCA: Liability under the Trump Administration’s tariff regime

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Tariff enforcement meets the FCA: Liability under the Trump Administration’s tariff regime

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Business as usual: The DOJ’s Civil Cyber-Fraud Initiative continues under the new Administration

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Business as usual: The DOJ’s Civil Cyber-Fraud Initiative continues under the new Administration

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Anti-Kickback Statute liability revisited

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Anti-Kickback Statute liability revisited

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State of play: State AGs ramp up FCA enforcement

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State of play: State AGs ramp up FCA enforcement

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Join our live webinar on March 12 at 2 p.m. ET to learn about the biggest trends and key areas of risk for companies

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Join our live webinar on March 12 at 2 p.m. ET to learn about the biggest trends and key areas of risk for companies

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The developing circuit split over objective falsity following SuperValu

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The developing circuit split over objective falsity following SuperValu

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Looking ahead

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Looking ahead

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About the Hogan Lovells Investigations, White Collar and Fraud team

Our award-winning team handles all issues relating to enforcement, whistle-blowing, criminal liability, regulatory violations, tax investigations, and asset recovery. We pursue and defend claims against executive boards, and we craft internal programs and policies that comply with global legislation.

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Band 2: False Claims Act

Chambers USA, 2022 – 2025

Ranked #2 in The GIR 30

Global Investigations Review, 2025

The Elite: Corporate Crime & Investigations

Chambers USA, 2021 – 2025