For more than 160 years, the False Claims Act (FCA) has been the federal government’s primary tool to combat fraud. In 2025, the U.S. Department of Justice (DOJ) underscored just how powerful — and profitable — the FCA can be, announcing a record-shattering $6.8 billion in government recoveries driven largely by health care fraud cases. Now, the Trump administration is using the FCA as a tool to eliminate what it considers to be illegal diversity, equity, and inclusion (DEI) programs. The question companies should be asking moving into 2026 is whether failure to comply with the Trump administration’s interpretation of civil rights laws presents a new level of risk. Indeed, a new frontier of potential liability under the FCA — with its treble damages and potentially astronomical statutory penalties — may become the future of enforcement.