In brief
On March 16, 2026, the US Administration announced a new multi‑agency fraud enforcement initiative tasked with identifying and eliminating fraud in federally funded programs. This initiative will have significant implications for companies, state and local governments, healthcare providers, educational institutions, and all recipients of federal funds.
With at least a dozen federal agencies participating and new mandates to accelerate False Claims Act (FCA) investigations, this initiative is poised to reshape the enforcement landscape. Clients should expect increased scrutiny, more subpoenas and information requests, rigorous FCA investigations, and a surge in whistleblower activity.
Baker McKenzie’s False Claims Act and Government Enforcement team is closely monitoring these developments and stands ready to help clients navigate the heightened risks.
Key developments
1. New anti-fraud task force spanning a dozen agencies
President Trump’s executive order establishes a task force designed to coordinate fraud oversight and enforcement across agencies including the Department of Justice (DOJ), Treasury, HHS, Education, HUD, Labor, DHS, SBA, OMB, and multiple Inspectors General.
The stated goals include:
- Increasing information sharing and coordinated investigations among federal, state, and local authorities
- Developing minimum anti-fraud requirements by May 16
- Releasing a measurable implementation plan by June 14
- Enhancing oversight of state-administered federally funded programs (healthcare, housing, nutrition, etc.)
This level of inter-agency integration is expected to materially increase the speed and volume of fraud probes.
2. DOJ directed to promote whistleblower activity
The executive order calls for the Attorney General to “take appropriate action to promote whistleblower activity” under the FCA and to ensure “prompt review” of whistleblower submissions.
Experts expect:
- An uptick in FCA filings, including lower-dollar matters that historically might have been declined
- Increased pressure on U.S. Attorney’s Offices to pursue a broader range of cases
- Greater incentives for whistleblowers and relators’ counsel to bring claims
For companies receiving federal funds, this could translate into more investigations, more litigation, and greater exposure.
3. National Fraud Enforcement Division at DOJ
A newly created National Fraud Enforcement Division, led by recently confirmed Assistant Attorney General Colin McDonald, is expected to coordinate directly with the White House task force.
While DOJ has not formally confirmed certain comments regarding the division’s reporting structure, observers anticipate:
- A more centralized, data-driven approach to identifying national fraud patterns
- Closer cooperation with state and local law enforcement
- Potential political scrutiny over enforcement priorities, increasing public and regulatory attention
4. Heightened enforcement across key sectors
Based on public reporting and expert commentary, clients should anticipate immediate scrutiny in the following areas:
- Healthcare & Life Sciences
- Claims submitted to Medicare/Medicaid
- Telehealth and digital health services
- Managed care plan billing and data submissions
- Grants, research funding, and COVID-19 residual programs
- Government contracting
- Procurement integrity and billing practices
- Small Business Administration (SBA) certifications
- Defense contracting risks, especially involving cybersecurity requirements
- State & local governments
- Administration of federally funded programs (housing, education, food assistance)
- Grant management, internal controls, and reporting requirements
Compliance and risk mitigation: What organizations should do now
In light of the expanded enforcement posture, organizations should consider:
1. Immediate compliance review
- Reassess policies and procedures related to:
- Billing and claims submission
- Grant management
- Procurement and subcontractor oversight
- Internal reporting mechanisms
2. Strengthening internal controls and fraud detection implement or enhance:
- Data analytics tools for anomaly detection
- Third-party due diligence protocols
- Program integrity reviews for high-risk funding streams
3. Preparing for increased subpoenas and RFIs organizations should rehearse and update:
- Government inquiry response protocols
- Document retention plans
- Employee training for interactions with investigators
4. Reassessing whistleblower readiness given DOJ’s push for whistleblower activity:
- Ensure internal reporting channels are accessible and trusted
- Conduct prompt and well-documented internal investigations
- Remediate issues before they escalate to external whistleblowers
How Baker McKenzie can help
Baker McKenzie has a market-leading False Claims Act and Government Enforcement practice, with deep experience defending FCA investigations, conducting internal reviews, and advising clients on compliance with complex federal funding and procurement regimes.
We regularly work with clients across healthcare, government contracting, financial services, technology, education, and public sector entities, and our global platform positions us to advise on cross-border funding and fraud risk issues.
We can assist with:
- FCA defense and DOJ/Inspector General investigations
- Internal investigations and whistleblower response
- Proactive compliance reviews tied to the new federal requirements
- Government contract counseling
- Crisis and enforcement response planning
Looking ahead
With the US Administration prioritizing fraud enforcement at a national scale and empowering DOJ to expand FCA and whistleblower actions, organizations receiving federal funds face a significantly more rigorous oversight environment.
Baker McKenzie is monitoring implementation of the task force, forthcoming minimum anti‑fraud requirements, and the operational structure of DOJ’s new fraud division. We will continue to provide updates as the enforcement landscape evolves.
If you have questions about how these developments may affect your organization — or if you would like support assessing your compliance posture — please contact your Baker McKenzie relationship partner or any member of our False Claims Act or Government Enforcement teams.