On May 19, 2025, the DOJ announced the establishment of the “Civil Rights Fraud Initiative,” which seeks to use the False Claims Act (FCA) to investigate, and possibly take civil action against, recipients of federal funds that knowingly violate federal civil rights law. The Trump administration’s position that, among other things, diversity, equity and inclusion (DEI) programs may violate federal civil rights laws exposes those who operate such programs to potential FCA liability.