You Heard It Here First: Arnold & Porter Launches Its Cyber FCA Tracker

With the U.S. Department of Justice’s (DOJ) Civil Cyber-Fraud Initiative picking up some steam, we at Qui Notes thought our readers might find it helpful to have a single source that reports on all cyber FCA resolutions and provides links for additional information related to each resolution. And so we’ve developed the Arnold & Porter Cyber FCA Tracker.

Since the initiative was launched in October 2021, DOJ and relators have targeted companies doing business with the federal government in a variety of industries: defense, medical devices, private equity, and education, to name a few. To serve as a quick reference on each resolution, the tracker identifies the type of company, resolution type, settlement amount (if applicable), cyber-related allegations, and key concepts (such as personal health information (PHI), NIST SP 800-171, or ISO). We hope our readers will find the tracker useful, and we welcome reader input on any potential improvements. We have also linked to Qui Notes Blog posts analyzing the cyber settlements included in the tracker, so the tracker serves as a useful one-stop location where you can find our ongoing analyses of cyber FCA issues.

Arnold & Porter represents clients across industry sectors in cyber FCA matters and provides advice on cybersecurity compliance matters more generally. If you have any cyber FCA-related questions or concerns, we are available to answer questions and provide guidance.

© Arnold & Porter Kaye Scholer LLP 2025 All Rights Reserved. This Blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.