Federal Analysis
DOJ Strengthens Cybersecurity FCA Enforcement
March 11, 2026
The Department of Justice (DOJ) reported a record-breaking $6.8 billion in False Claims Act (FCA) settlements and judgments for fiscal year 2025, with a marked increase in enforcement actions related to cybersecurity compliance. Cybersecurity-related FCA recoveries have more than tripled over the past two years, underscoring the DOJ's sustained focus on holding contractors and grantees accountable for false certifications of cybersecurity compliance, even in the absence of actual data breaches. Notable settlements include a $11.2 million TRICARE military health benefits contractor settlement, a $9.8 million medical device manufacturer settlement for inadequate product cybersecurity, and an $8.4 million defense contractor settlement for failure to meet Department of War cybersecurity requirements.
- Why this matters: Procurement professionals and contractors must prioritize accurate cybersecurity compliance certifications to avoid FCA liability and significant financial penalties.
- Agencies and contractors should review and strengthen cybersecurity policies and reporting practices to align with DOJ enforcement priorities.
- This trend indicates increased DOJ scrutiny on cybersecurity representations in government contracts, affecting risk management and contract performance.
- Legal and compliance teams should engage proactively with cybersecurity frameworks and ensure transparency in certifications to mitigate FCA exposure.
The DOJ is not seeking to punish companies that are victims of sophisticated attacks, which can occur even when entities are completely compliant with all applicable cyber regulations.
— Brenna E. Jenny, Deputy Assistant Attorney General
Cybersecurity fraud remains a key FCA enforcement priority.
— Brenna Jenny, Deputy Assistant Attorney General
Agencies
Department of Justice, Department of War, Federal Acquisition Regulation, Defense Federal Acquisition Regulation Supplement, National Aeronautics and Space Administration
Vendors
Health Net Federal Services LLC, Centene Corporation, Illumina Inc., Raytheon Companies, Nightwing Group
Contracts
$11.2 million, $9.8 million, $8.4 million