Top 10 Non-Healthcare False Claims Act Recoveries in 2025

By the Constantine Cannon Whistleblower Team

As the Department of Justice (DOJ) trumpeted in its annual False Claims Act roundup, 2025 was another record year for False Claims Act recoveries.  The Government recovered $6.9 billion last year, the largest single-year amount ever under the statute.  This brings the total tally of False Claims Act recoveries to more than $85 billion since 1986.

More than 80% of last year’s haul (roughly $5.7 billion) came from matters involving healthcare-related fraud.  It has been that way for years, with healthcare cases accounting for roughly $60 billion of all False Claims Act recoveries since 1986.  It is further reflected in our Top 10 listing of 2025 False Claims Act recoveries, with 7 healthcare cases making the list, including 5 of the top 6 spots.  Check out our Top 10 Listing of 2025 Healthcare-Related False Claims Act recoveries to see the other major healthcare fraud recoveries from last year.

But last year’s False Claims Act recoveries were not limited to actions involving healthcare fraud.  There were plenty of notable recoveries outside the healthcare space.  Most of them involved Government procurement fraud, harking back to the statute’s origins during the Civil War.  Congress passed the False Claims Act to go after war profiteers attempting to defraud the Union Army with the likes of lame mules and sawdust munitions.

Below is our listing of last year’s Top 10 non-healthcare related False Claims Act recoveries.  As expected, most of them involved fraud in government procurement contracts.  But there are several that fall outside this traditional enforcement area and relate to specific areas the Government has targeted as high priority.  These include customs fraud, cybersecurity fraud, and fraud relating to COVID-relief and the PPP program (Paycheck Protection Program) in particular.

Also as expected, whistleblowers originated many of the actions in the Top 10 listing.  This is consistent with the outsized role whistleblowers have played in supporting the government in its False Claims Act enforcement.  Almost 80% of the recoveries last year (roughly $5.3 billion) came from whistleblower-initiated actions.  And since 1986 — when Congress amended the statute to significantly increase the protections and financial incentives for whistleblowers to step forward — whistleblowers have accounted for more than 70% (roughly $61 billion) of all recoveries.

So, without further ado, here is our Top 10 list, with a link to our original post describing the action and resulting settlement in more detail:

• • No. 1 – Q Link ($110M).  On July 28, DOJ announced that Florida-based telecommunications provider Q Link Wireless and its owner Issa Asad would pay roughly $110 million to settle criminal and civil charges of violating the False Claims Act by defrauding the FCC’s Lifeline Program designed to assist low-income consumers with their telecommunications needs.  According to the Government, Q Link and Asad orchestrated a scheme of enrolling Lifeline customers who neither needed nor used their phones, including customers who never even had activated phones.

• • No. 2 – Horizon Healthcare ($100M).  On November 14, New Jersey Attorney General Matthew Platkin announced that Horizon Healthcare Services (known as Horizon Blue Cross Blue Shield of New Jersey) would pay $100 million to settle allegations of violating the New Jersey False Claims Act by overcharging the State on its contract to administer the State’s employee benefit programs.  It is New Jersey’s largest non-Medicaid False Claims Act settlement ever.  The State’s action originated from a lawsuit filed by six whistleblowers under the qui tam provisions of the New Jersey False Claims Act.  As part of the settlement, the State agreed to provide five of the whistleblowers — Kevin Lyons, Patrick Colligan, Mark Kovar, Mark Flores, and Vince Flores — a $12 million whistleblower award from the proceeds of the settlement.

• • No. 3 – L3 Technologies ($62M).  On May 22, DOJ announced that Utah-based defense contractor L3 Technologies would pay $62 million to settle charges it violated the False Claims Act by overcharging the Department of Defense on various military contracts.  According to the Government, L3 did not comply with TINA (Truth in Negotiations Act) transparency requirements and inflated its cost and pricing data for labor, material, and other costs.

• • No. 4 – Ceratizit ($54.4M). On December 18, DOJ announced that North Carolina-based Ceratizit USA would pay $54.4 million to settle allegations it violated the False Claims Act by failing to pay duties it owed Customs and Border Protection on the products it imported from China.  The allegations originated in a whistleblower lawsuit filed by Mark Stover under the qui tam provisions of the False Claims Act.  He will receive a whistleblower award of roughly $9,750,000 from the proceeds of the Government’s recovery.

• • No. 5 – Lockheed ($41.3M). On February 6, DOJ announced that Maryland-based defense contractor Lockheed Martin would pay roughly $30 million to settle allegations of violating the False Claims Act and TINA by overcharging the government on several F-35 military aircraft contracts.  This is on top of the $11.3 million the company previously paid the Department of Defense (DoD) for similar pricing misconduct on the same contracts.  According to the government, in negotiating these contracts, Lockheed failed to provide DoD with accurate and complete cost and pricing data from Lockheed’s suppliers, allowing Lockheed to secure significantly inflated pricing terms on these DoD contracts.  The allegations originated in a whistleblower lawsuit filed by former Lockheed auditor Patrick Girard, who will receive a whistleblower award of roughly $8 million from the proceeds of the Government’s recovery.

• • No. 6 – DynCorp ($21M). On April 9, DOJ announced that Virginia-based government contractor DynCorp International would pay $21 million to settle allegations it violated the False Claims Act by overbilling the State Department under its longtime contract to train Iraqi “CIVPOL” police forces.  According to the government, one of DynCorp’s primary subcontractors charged excessive and unsupported rates for hotel lodging and guard, translator, driver, and supervisor services.  The government claimed DynCorp was aware of these inflated charges (or should have been aware of them) and by passing them through to the State Department, DynCorp violated its obligations as the prime government contractor.

• • No. 7 – Patrick Walsh ($20M).  On March 12, DOJ announced that Florida resident Patrick Walsh and his companies would pay roughly $20 million to settle charges they violated the False Claims Act by defrauding the PPP and Economic Injury Disaster Loan (EIDL) program.  Walsh and his companies secured roughly $7.8 million in loans by misrepresenting employee rosters and payrolls and Walsh used the loans for personal purposes, including buying a private island, investing in Texas oil interests, and paying off personal debts.  The allegations originated in a whistleblower lawsuit filed by Andrew Hersh, who performed information technology services for Walsh.  He will receive an undisclosed whistleblower award from the proceeds of the government’s recovery.

• • No. 8 – DRI Relays ($15.7M). On April 1, DOJ announced that TE Connectivity Corporation subsidiary DRI Relays would pay $15.7 million to settle allegations it violated the False Claims Act by supplying military parts that did not meet military specifications.  According to the government, DRI billed the Defense Department for military grade electrical relays and sockets when it knew those parts did not meet the necessary testing requirements to be deemed military grade.

• • No. 9 – Dana-Farber ($15M). On December 16, DOJ announced that Boston-based Dana-Farber Cancer Institute would pay $15 million to settle allegations it violated the False Claims Act by fraudulently securing and using National Institutes of Health (NIH) research grants.  According to the government, Dana-Farber secured NIH grants through false and misleading statements and spent grant funds on unallowable expenses.  The allegations originated in a whistleblower lawsuit filed by Sholto David, a microbiologist from Wales, who identified what he viewed as scientific research fraud.  He will receive a whistleblower award of roughly $2.6 million from the proceeds of the government’s recovery.

• • No. 10 – Hill Associates ($14.75M).  On July 14, DOJ announced Maryland-based federal contractor Hill Associates would pay at least $14.75 million to settle allegations it violated the False Claims Act by violating several key provisions of its General Services Administration (GSA) contract for information technology (IT) services.  According to the Government, Hill billed federal agencies for: (i) IT personnel who did not have the required experience or education, (ii) cybersecurity and other IT services that were outside the contract scope, and (iii) generally unapproved fees.

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Constantine Cannon whistleblower attorney Dan Noel said the Top 10 listing provides a good cross-section of the type of non-healthcare cases the Government is targeting.  “DOJ has made it very clear that its fraud enforcement efforts extend well beyond Medicare fraud and other healthcare-related misconduct,” he said.  “Government contract fraud very much remains a top Government priority.”

Noel added that “customs fraud also sits very high on DOJ’s list,” noting that the $54.4 million the Government recovered in the Ceratizit matter (number 4 on the Top 10 list) is the largest customs fraud recovery ever, and just one of numerous customs fraud recoveries DOJ secured last year.  Noel says that may explain why he has received more customs fraud whistleblower intakes over the last six months than ever before.  “DOJ has made it very clear to us they want to hear from customs fraud whistleblowers.”

Constantine Cannon has substantial experience representing whistleblowers under the False Claims Act.  If you would like to learn about our various whistleblower successes or what it means to be a whistleblower under the False Claims Act, please do not hesitate to contact us.  We will connect you with an experienced member of our whistleblower team for a free and confidential consultation.  You could be the whistleblower who uncovers the next big thing the Government goes after!

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