In the first nine months of 2026, the Department of Justice (“DOJ”) issued a department-wide corporate enforcement policy, created a new fraud division, launched a White House-level task force, executed a sizable healthcare fraud takedown, and opened a multi-agency fraud detection center. The message: investigating and prosecuting fraud involving government funds now is a central DOJ priority. Below is a chronological overview and some practitioner takeaways.

1. DOJ Issuance of the Corporate Enforcement Policy (March 2026)

On March 10, 2026, DOJ released its first-ever department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), refining or replacing prior component-specific and U.S. Attorney’s Office–specific corporate enforcement policies.[1] It applies to all DOJ components except the Antitrust Division, which maintains its own policy.[2]

The CEP establishes three potential resolution lanes for companies that discover and report misconduct:

Lane 1 — Declination. A company that voluntarily self-discloses to an appropriate DOJ criminal component, fully cooperates, timely remediates, and has no aggravating circumstances (such as recidivism or pervasive misconduct) will receive a presumptive declination of prosecution. The company must still pay disgorgement/forfeiture and restitution.

Lane 2 — “Near Miss” NPA. If a company fully cooperates and timely remediates but falls short on meeting the “voluntary self-disclosure” factors, or has aggravating factors warranting a criminal resolution which are not particularly egregious, DOJ shall provide a non-prosecution agreement with (1) a term of fewer than three years, (2) no independent compliance monitor, and (3) a fine reduction of 50–75% off the low end of the U.S. Sentencing Guidelines fine range.

Lane 3 — Discretionary Resolution. Where a company does not qualify for either of the above lanes, prosecutors retain discretion over the resolution form, but any fine reduction is capped at 50% off the U.S. Sentencing Guidelines fine range.

Additional practitioner takeaway. Companies can now benefit from a “One DOJ” approach to self-disclosures: a good-faith disclosure to the wrong DOJ component will still qualify for credit, if the matter is later referred to the correct component. Disclosures to federal regulatory agencies or state and local governments generally do not qualify but may if “appropriate under the circumstances.”

2. White House Creation of the Task Force to Eliminate Fraud (March 2026)

On March 16, 2026, President Trump signed Executive Order (“EO”) 14395 establishing the Task Force to Eliminate Fraud within the Executive Office of the President.[3] The Task Force is chaired by Vice President JD Vance.

Key takeaways. The Task Force covers fraud, waste, and abuse across every federally funded benefit program, including those jointly administered with states. Agencies face fixed deadlines: 30 days to identify high-risk transactions, 60 days to adopt anti-fraud requirements, 90 days to submit implementation plans. The EO authorizes withholding federal funds from non-compliant jurisdictions; DOJ has already withheld over a billion in Medicaid funding to one State. The Attorney General is separately directed to promote qui tam actions under the False Claims Act.

3. DOJ Creation of the National Fraud Enforcement Division (April 2026)

On April 7, 2026, (then) Acting Attorney General Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (“Fraud Division”), led by Assistant Attorney General Colin McDonald. The Division assumed operational control over the Criminal Division’s Tax Section, Health Care Fraud Unit, and Market, Government, and Consumer Fraud Unit.

Key takeaways. The Division’s five priority sectors are public trust and financial integrity, healthcare, internal revenue, global trade and commerce, and corporate misconduct. Staffing goal is roughly 500 attorneys and support by late August 2026, supplemented by a $300 million grant program placing state and local prosecutors as Special Assistant U.S. Attorneys. Each U.S. Attorney’s Office must embed an experienced prosecutor in the Division.

4. DOJ National Healthcare Fraud Takedown (June 2026)

On June 23, 2026, DOJ announced the 2026 National Health Care Fraud Takedown, which resulted in charges against 455 defendants, including 90 doctors and licensed medical professionals, across 56 federal districts and 45 states and territories, and involving more than $6.5 billion in alleged false claims.[4] All 50 state Medicaid Fraud Control Units participated.

Key takeaways. The underlying case allegations reveal recurring patterns: wound care (allograft) kickback and overbilling schemes; hospice care fraud involving enrollment of non-terminally ill or deceased patients; behavioral health billing fraud; substance abuse treatment fraud; and illegal opioid distribution by licensed medical professionals.

5. Creation of the National Fraud Detection Center (August 2026)

On August 24, 2026, DOJ announced the launch of the National Fraud Detection Center (“NFDC”), a multi-agency and prosecutor-led group designed to generate criminal leads and drive more impactful fraud prosecutions.[5]

Key takeaways. The NFDC merges analytical resources from the normal federal law enforcements agencies but also over a dozen Inspectors General into a single platform. The platform uses AI and advanced analytics to flag anomalous billing, eligibility irregularities, and multi-program activity across agencies. This detection capability conceivably compresses the timeline for companies to make voluntary self-disclosure under the CEP ahead of government awareness.

Conclusion

These developments collectively signal that fraud enforcement involving government funds now sits at the center of DOJ’s agenda, and is backed by dedicated resources, more centralized leadership, and with the benefit of AI analysis. Sectors most exposed — healthcare providers billing Medicare or Medicaid, government procurement contractors, federal grant and benefit recipients, and trade-dependent companies — should see 2026 as a reset.

Chris Dippel is a member of Kean Miller’s White-Collar Investigations & Criminal Defense group, where he defends and navigates clients through a wide range of matters involving criminal allegations of financial and securities fraud, health fraud, theft of government funds, embezzlement, public corruption, and other forms of white-collar crime. Chris is a former federal and state prosecutor who has years of experience with the criminal justice process, from investigation to trial.

[1] https://www.justice.gov/dag/media/1430731/dl?inline.

[2] https://www.justice.gov/opa/pr/department-justice-releases-first-ever-corporate-enforcement-policy-all-criminal-cases.

[3] https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud.

[4] https://www.justice.gov/opa/pr/national-health-care-fraud-takedown-results-455-defendants-charged-connection-over-65.

[5] https://www.justice.gov/opa/pr/department-justice-announces-launch-national-fraud-detection-center-combat-fraud-against.