DOJ Signals Aggressive Fraud Enforcement—With Health Care and Tariff Fraud in Focus
The Department of Justice continues to sharpen its focus on fraud enforcement. Whistleblowers and data analytics will continue to play central roles in that effort.
On October 1, 2026, Assistant Attorney General Colin M. McDonald, who leads DOJ’s National Fraud Enforcement Division (NFED), issued a memorandum directing an aggressive approach to corporate enforcement across the Division’s fraud portfolio. McDonald’s memo directs prosecutors to prioritize health care fraud, significant evasion of government revenue, and tariff evasion, among other areas. It also directs Division leadership to develop policies and programs that incentivize whistleblowers to bring credible fraud information to the government.
The October 1 memo follows DOJ’s August launch of the National Fraud Detection Center, which brings together prosecutors, law enforcement, and analytical capabilities from across the government to identify fraud and generate investigative leads. Taken together, these developments show DOJ bringing together prosecutors, sophisticated analytics, and whistleblower information in its approach to fraud enforcement.
Wound care and tariff enforcement are prime illustrations of how that approach can work in practice.
Wound Care
Wound care, particularly Medicare billing involving amniotic wound allografts, has become a target of aggressive DOJ health care fraud enforcement.
In its 2026 National Health Care Fraud Takedown, DOJ announced charges against 11 defendants across six federal districts involving billions of dollars in allegedly fraudulent skin graft claims. The alleged schemes included kickbacks, medically unnecessary applications, and excessive use of expensive allografts.
DOJ credited its Health Care Fraud Unit’s Data Analytics Team with identifying the spike in allograft payments that led to prosecutions. That is significant for potential whistleblowers. Data can identify an unusual billing pattern. Information from an insider can help show what is driving that pattern.
A provider’s billing may show extraordinary allograft utilization, but physicians, nurses, sales representatives, marketers, billing personnel, and others may be able to add important context. Those insiders can explain, for example, whether patients actually needed repeated applications, how particular products were selected, whether financial incentives influenced treatment, and whether the medical records accurately reflected what occurred. Those facts can turn an abnormal billing pattern into an actionable fraud case.
Tariff and Customs Fraud
DOJ also is taking an aggressive approach to tariff and customs fraud under the False Claims Act. In July, DOJ announced that its Trade Fraud Task Force had surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in less than a year.
A recent District of New Jersey case illustrates the critical role that whistleblowers play in these cases. Redi-Bag USA and its CEO agreed to pay $7.3 million to resolve allegations that they evaded antidumping duties on Chinese-made plastic bags by transshipping them through Hong Kong and misrepresenting their country of origin. A former contracted sales representative, who received approximately $1.33 million from the settlement, brought the case under the False Claims Act.
Redi-Bag shows how a whistleblower’s inside information can provide critical assistance in tariff fraud enforcement. Employees, customs and logistics professionals, suppliers, competitors, and others may know where goods actually were manufactured, why they were routed through another country, what customs brokers were told, or whether management knew that import declarations were inaccurate. That information may provide evidence of transshipment, undervaluation, misclassification, or other efforts to avoid duties owed to the United States.
What This Means for Whistleblowers
DOJ’s recent actions and directives underscore the important role whistleblowers play as the government expands its use of data analytics to identify potential fraud. People with first-hand knowledge can provide crucial context about how companies made their decisions, what they communicated internally and externally, how practices and compliance measures were implemented or flouted, and whether conduct was intentional.
Timing is critical for potential whistleblowers. Someone with credible information about fraud should consider seeking advice promptly rather than waiting for an investigation or enforcement action to become public. Coming forward early can give the government valuable information while it is identifying and investigating potential misconduct and can preserve options that may become more limited as others report the same conduct or the government’s investigation advances.
Getnick Law is one of the nation’s preeminent whistleblower practices, having recovered more than $1.5 billion for the government and record awards for its clients. If you have first-hand information that may explain unusual wound care or Medicare billing, or how a company is avoiding tariffs or customs duties, contact Getnick Law for a confidential discussion about whether that information may support a whistleblower case.