New USDOJ memorandum titled "Civil Rights Fraud Initiative"

On May 19, 2025, the U.S. Department of Justice, Office of the Deputy Attorney General, issued a memorandum titled 'Civil Rights Fraud Initiative.' On June 23, 2025, the Department of Justice (DOJ) updated the original press release from May, reaffirming the initiative’s launch and its aggressive enforcement intentions.  The Memorandum reflects the DOJ commitment to enforcing federal civil rights laws through ”vigorous enforcement of the False Claims Act."  This initiative specifically targets recipients of federal funds, including universities, contractors, and other entities that knowingly violate civil rights laws while certifying compliance to the government.  

The memorandum underscores that such violations may lead to substantial liability, including treble damages and penalties. It also highlights the Department of Justice’s intent to coordinate enforcement efforts across its divisions and with other federal and state agencies. Additionally, the DOJ strongly encourages individuals with knowledge of discriminatory practices to file whistleblower lawsuits under the False Claims Act, alleging that a person or entity has defrauded the government through federal programs or contracts.

We recommend that all federal contractors and organizations receiving federal grants review their contracts, compliance programs, and policies to ensure adherence to all applicable civil rights requirements and avoid potential exposure under the False Claims Act. For further information or guidance, contact attorney Michelle Kantor, the Chair of McDonald Hopkins' Federal Government Contract Group.