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A Year in Review: Top 5 Biggest Whistleblower Settlements of 2025
Table of Contents
As 2025 draws to a close, the Department of Justice’s (DOJ) False Claims Act enforcement offers a revealing snapshot of both continuity and escalation in federal fraud policing. Senior DOJ officials have repeatedly emphasized that FCA enforcement is not episodic or reactive, but a permanent fixture in the government’s effort to combat fraud, waste, and abuse across federal program.
The past year reflects a deliberate focus on high impact sectors, particularly healthcare, government contracting, and increasingly, customs and tariff enforcement.
Against that backdrop, these five FCA settlements of 2025 illustrate how aggressively the statute continues to shape corporate accountability and whistleblower driven enforcement.
Healthcare Fraud Enforcement
Healthcare fraud remained the single most significant driver of False Claims Act enforcement in 2025, reflecting the federal government’s continued focus on safeguarding publicly funded health programs. DOJ leadership has emphasized that healthcare fraud inflicts not only financial harm, but also tangible patient harm, reinforcing the agency’s willingness to pursue aggressive remedies under the FCA.
Enforcement actions this year spanned a wide range of alleged misconduct, including improper billing, kickback arrangements, manipulation of reimbursement models, and false certifications tied to compliance obligations.
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Amniotic Wound Graft Mega-Scheme ($1.2 Billion)
One of the most significant healthcare fraud matters of 2025 centered on a massive wound graft scheme that prosecutors described as one of the largest Medicare frauds ever uncovered. According to DOJ allegations, the owners of multiple wound care companies orchestrated a nationwide scheme to bill Medicare and other federal healthcare programs for medically unnecessary amniotic skin grafts, primarily targeting elderly and hospice patients. (1)
Over an 18 month period, the defendants allegedly submitted more than $1.2 billion in false claims and received approximately $615 million in payments from federal healthcare programs. Prosecutors emphasized that the conduct went beyond financial fraud by highlighting the physical harm inflicted on vulnerable patients subjected to painful and unnecessary procedures for profit. (1)
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We have previously examined this enforcement trend in greater detail, including the common red flags, billing tactics, and whistleblower dynamics associated with skin graft fraud under the False Claims Act.
For readers seeking a deeper understanding of how these schemes operate and how they are being prosecuted, our full discussion of skin graft fraud is available here.
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Pfizer Subsidiary Improper Physician Payments ($59.7 Million)
In January 2025, Pfizer agreed to pay nearly $60 million to resolve FCA allegations tied to conduct by its subsidiary Biohaven Pharmaceutical Company prior to Pfizer’s acquisition for the company. (2) The settlement centered on Biohaven’s marketing of Nurtec ODT, a migraine medication, and alleged violations of the Anti-Kickback Statute (AKS) stemming from physician speaker programs that occurred between March 2020 and September 2022. (3)
The DOJ alleged that many of the programs involved repeat speakers, minimal or no substantive presentations, and compensation that exceeded fair market value, raising red flags that the payments functioned as unlawful kickbacks rather than bona fide consulting arrangements.(3) Because claims resulting from kickback tainted prescriptions are considered false under the FCA, the government asserted that these practices caused the submission of false claims to Medicare.
Our firm has previously explored this settlement in an article covering the general discourse surrounding illegal kickback schemes in healthcare. For those interested in reading further into said schemes, our coverage of the topic can be found here.
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Walgreens Opioid Dispensing and FCA Settlement ($350 Million)
In April 2025, Walgreens agreed to pay up to $350 million to resolve allegations that it filled millions of unlawful opioid and other controlled substance prescriptions and then submitted false claims to federal healthcare programs for reimbursement. The Department of Justice alleged that Walgreens dispensed prescriptions lacking a legitimate medical purpose or issued outside the usual course of professional practice, including excessive quantities, early refills, and prescriptions involving the especially dangerous combination of opioids, benzodiazepines, and muscle relaxants. (4)
Brown LLC played a significant role in helping secure this resolution on behalf of whistleblowers who brought the matter forward. (5) The settlement includes a base payment of $300 million, with an additional $50 million contingent on future corporate transactions before 2032, and resolves multiple whistleblower lawsuits filed by former Walgreens employees, who will share a portion of the recovery. (4)
For a more detailed breakdown of this matter and Brown LLC’s involvement, see our full article here.
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Gilead Sciences Kickback Settlement ($202 Million)
In April 2025, Gilead Sciences agreed to pay $202 million to resolve False Claims Act allegations that it used physician speaker programs to pay unlawful kickbacks and induce prescriptions of its HIV medications. (6)
According to prosecutors, the scheme centered on Gilead’s marketing of Stribild, Genvoya, Complera, Odefsey, Descovy, and Biktarvy, with speaker programs frequently held at luxury restaurants and repeated on the same topics with little educational value. (6) DOJ alleged that high volume prescribers received tens or hundreds of thousands of dollars in payments and that Gilead’s internal controls failed to prevent sales driven inducements rather than legitimate education.
Under the settlement, Gilead agreed to pay approximately $176.9 million to the federal government, with the remaining balance paid to participating states to resolve related Medicaid claims, bringing the total resolution to $202 million. (6)
The DOJ’s Escalated Enforcement Against Tariff and Customs Fraud
As discussed in our article on the role of False Claims Act whistleblower cases in combating customs fraud, the DOJ has increasingly relied on whistleblowers to uncover complex trade violations. (7) That enforcement focus is illustrated by the Ceratizit settlement below, which shows the DOJ applying the FCA to alleged tariff evasion with the same intensity long seen in healthcare enforcement.
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Ceratizit USA LLC Customs Duty Evasion ($54.4 Million)
In December 2025, Ceratizit USA LLC, a North Carolina based distributor of tungsten carbide products, agreed to pay $54.4 million to resolve False Claims Act allegations that it knowingly evaded customs duties on imports from the People’s Republic of China. (8)
According to the Department of Justice, Ceratizit avoided paying applicable Section 301 tariffs by falsely declaring that Chinese manufactured tungsten carbide products originated in Taiwan rather than China.(8)
The settlement resolved a whistleblower lawsuit filed under the FCA, with the relator receiving approximately $9.75 million of the recovery. DOJ officials framed the resolution as part of a broader enforcement effort to ensure importers comply with tariff obligations and to deter schemes designed to evade trade laws through misrepresentation and transshipment. (8)
Conclusion
The largest FCA settlements of 2025 reflect the DOJ’s continued view of the FCA as one of its most effective tools for enforcing accountability across a wide range of industries. From healthcare and pharmaceutical marketing to opioid dispensing, customs duties, and tariff evasion, enforcement actions this year underscore a sustained focus on protecting federal programs, taxpayer funds, and market integrity.
These cases also highlight the critical role whistleblowers play in bringing complex and often concealed fraud schemes to light. As enforcement priorities expand and financial recoveries grow, individuals with inside knowledge of fraud remain essential to the government’s efforts.
If you believe you have information about potential fraud against the government, we encourage you to reach out to Brown, LLC to discuss your concerns in confidence and learn how we can assist in evaluating and pursuing a potential whistleblower claim.
[2] DOJ – Biohaven Settlement Agreement
[5] Brown LLC – Top 3 Kickback Schemes Hiding in Plain Sight – 2025 Whistleblower Edition
[7] Brown LLC – The Role of False Claims Act Whistleblower Cases in Combatting Customs Fraud
