DOJ Highlights 2025 Fraud Enforcement Activity as New DOJ Division for National Fraud Enforcement Announced

On January 22, 2026, DOJ’s Criminal Division Fraud Section announced the release of its Year in Review for 2025, which provides an overview of the Section’s enforcement activities over the prior year and underscores the Section’s priority initiatives. The Fraud Section reported charging more than 250 individuals, trying two dozen cases across 17 districts, and bringing 15 corporate enforcement actions across its portfolio, including matters involving large public companies. Those matters included federal program and procurement fraud, trade and customs fraud, healthcare fraud, and market manipulation and securities fraud, and they reflect continued emphasis on individual accountability and trial readiness. The 2025 Year in Review also points to increased use of proactive data analysis to identify outlier patterns and develop investigations.

This Year in Review comes on the heels of the White House’s announcement on January 8, 2026, of the Department of Justice’s Division for National Fraud Enforcement, a new DOJ division intended to centralize and elevate the federal government’s approach to fraud enforcement. The following day, the Treasury Secretary announced a set of related Treasury-led initiatives focused on alleged government benefits fraud in Minnesota, including actions by the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service.

These developments track DOJ’s recent emphasis on government program and procurement fraud as a core white-collar enforcement priority. (See our Legal Update, DOJ Announces White-Collar Enforcement Priorities and Revised Policies.)

While key implementation details remain unclear, the announcement of the Division for National Fraud Enforcement and Treasury’s parallel measures, in addition to the trends highlighted in the 2025 Year in Review, signal sustained enforcement attention on fraud involving federal programs, federally funded benefits, and federal funding streams, supported by increased inter-agency coordination and expanded use of financial intelligence tools.

Division for National Fraud Enforcement: Scope and Responsibilities

The White House fact sheet describes the Division for National Fraud Enforcement as a nationwide criminal and civil fraud enforcement body. The Division is expected to enforce federal criminal and civil laws against fraud targeting federal government programs, federally funded benefits, businesses, nonprofits, and private citizens nationwide.

According to the fact sheet, the Division will be run by a new, Senate-confirmed Assistant Attorney General (AAG) who will be responsible for leading DOJ’s efforts to “investigate, prosecute, and remedy” fraud affecting the federal government, federally funded programs, and private citizens. The AAG’s stated responsibilities include overseeing multi-district and multi-agency fraud investigations, providing advice, assistance, and direction to US Attorneys’ Offices on fraud-related issues, and working closely with federal agencies and DOJ components to identify, disrupt, and dismantle fraud schemes across jurisdictions.

The fact sheet also states that the AAG will help develop and set national enforcement priorities and propose legislative and regulatory reforms as necessary to address systemic vulnerabilities, and will advise the Attorney General and Deputy Attorney General on significant, high-impact fraud investigations and related policy matters.

The fact sheet does not address how the Division for National Fraud Enforcement will interact with DOJ’s existing fraud enforcement structure, including fraud prosecutors in US Attorneys’ Offices and DOJ components that historically have handled many of the government’s largest fraud investigations and resolutions (such as, for example, the Criminal Division Fraud Section). As a practical matter, the impact of the new division will likely depend on (i) how quickly leadership is nominated and confirmed, and (ii) whether the Division is positioned primarily as a priority and policy setting hub, a litigating division, or a hybrid of the two.

What This Means for Companies, Nonprofits, and Financial Institutions

Fraud involving federal funds remains a principal enforcement focus

The White House fact sheet is explicit that the Division for National Fraud Enforcement will enforce criminal and civil laws against fraud targeting federal programs and federally funded benefits, and extends the framing to businesses and nonprofits as well as private citizens. Consistent with that framing, the Criminal Division Fraud Section’s 2025 Year in Review highlights sustained focus on conduct affecting the public funds: procurement and grant fraud, misuse of relief funds, trade and tariff evasion, and healthcare program fraud. For large corporations, these trends reinforce that enforcement risk may arise from supply chain and customs practices, government-facing certifications and submissions, and controls around data and emerging technologies. In practice, this may implicate a wide set of sectors that interact with federal funds, including healthcare and life sciences, higher education, housing-related entities, social services providers, fintech and payments providers that support benefit distribution, and nonprofits administering programs funded directly or indirectly through federal dollars.

Open questions remain about DOJ structure and process

The White House fact sheet sets out broad authority for the Division for National Fraud Enforcement and its AAG, but initially left open how the Division would be integrated into DOJ’s existing fraud enforcement structure, including reporting lines, investigative authority, and coordination with existing DOJ components. In a January 16 letter to Congress, DOJ described an initial implementation approach under which the fraud AAG would report to the Deputy Attorney General, the Division would be staffed using existing DOJ personnel, and no new appropriations would be required. DOJ also indicated that the role would be established by repurposing an existing assistant attorney general position. This approach differs from earlier public remarks suggesting White House supervision.

The Criminal Division Fraud Section’s Year in Review also reiterates DOJ’s continued reliance on established corporate enforcement frameworks (including the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy and related guidance on compliance programs and monitorships) when assessing cooperation credit and resolution terms. These details will matter for corporate targets, including how DOJ’s existing approaches to cooperation, remediation, and resolution will be applied in matters overseen or coordinated by the new Division.

Practical Steps to Consider

Organizations with meaningful exposure to federal funding streams or federally administered programs may wish to consider the following:

• Map key federal touchpoints and assign clear ownership: Conduct a risk assessment focused on government-facing revenue streams and incentives (for example, government contracts, reimbursement programs, trade and customs programs, tax payments or credits, and other government transactions), as well as third-party engagements supporting those activities.
• Review policies, procedures, control and training: Ensure policies, procedures, controls and training materials are updated to ensure compliance with laws relating to government contracts, procurement fraud and other government financial transactions or interactions, including consideration of whether the DOJ’s positions on certain areas of law have evolved or changed.
• Contract review and/or audit: Review contractual provisions, certifications and/or periodic attestations involving contracts with the government or otherwise involving government programs or other governmental interactions, and consider risk-based audits that could identify potential compliance risks.
• Confirm investigation-response readiness: Ensure preservation and collection protocols are current, privilege and escalation procedures are in place, as well as coordinated engagement across Legal, Compliance, Finance, and Internal Audit functions; confirm that whistleblower intake and anti-retaliation controls are operating effectively.
• Financial institutions and payments businesses review monitoring and SAR practices: Consider whether transaction monitoring, escalation criteria, and SAR drafting practices are calibrated to identify government-program and public-benefits fraud risks and reflect FinCEN’s stated filing guidance where relevant. Institutions that are subject to any FinCEN geographic targeting order should also confirm they can meet any additional reporting and recordkeeping requirements during the applicable effective period.