Statement from the Program Integrity Alliance on Executive Order 14390: Combating Cybercrime, Fraud, and Predatory Schemes
The Program Integrity Alliance welcomes the Administration's recognition that organized criminal networks pose an escalating threat to American public programs. Transnational criminal organizations have identified government payment systems as lucrative, low-risk targets, and they are exploiting them with growing sophistication and scale. Elevating this threat to the national agenda and directing coordinated action against these networks is a meaningful and necessary step.
The scope of the problem demands urgent attention. The Government Accountability Office estimates that the federal government loses up to $521 billion annually to fraud, concentrated in the large benefit and grant programs that distribute funds broadly and at speed. During the pandemic, criminal networks stole hundreds of billions of dollars using international cybercrime infrastructure and fraud rings operating across continents.
These are not isolated acts of opportunism. They are industrialized criminal operations operating through cyber channels. Sophisticated actors now deploy botnets, stolen and synthetic identities, automated claim-filing tools, and global money-laundering networks to simultaneously exploit vulnerabilities across multiple government programs. In many cases, fraudsters submit millions of claims before a single flag is raised.
The vulnerability is structural. Most federal payment systems were engineered to deliver benefits quickly and broadly. They were not designed to withstand coordinated, technology-enabled criminal assault. Fragmented data systems, outdated identity verification, legal barriers to responsible data sharing, and disbursement processes that release funds before risk can be assessed have created an environment where sophisticated actors can operate freely, at scale, and often without consequence.
Law enforcement is essential, but insufficient on its own. When billions of dollars exit government accounts before suspicious activity is detected, prosecution alone cannot recover what has already been lost. Meaningful fraud reduction requires pairing enforcement with systemic reforms that make programs structurally harder to exploit.
The Program Integrity Alliance calls on leaders in both the Executive Branch and Congress to pursue the following reforms:
Mandate pre-disbursement fraud detection. Most federal payment systems release funds before risk can be meaningfully evaluated, giving sophisticated fraud networks a structural advantage. Agencies must be required— and resourced—to implement real-time analytics capable of identifying and flagging suspicious activity before funds leave government accounts. Without this capability, even well-designed enforcement efforts are largely remedial, pursuing losses that have already occurred and are rarely recovered in full.
Establish clear accountability for program integrity. Agency leaders must own fraud prevention as an expectation of their role and be held accountable for safeguarding the funds they administer. Accountability should be built into leadership mandates and performance metrics, not treated as an afterthought.
Modernize data-sharing authority. Congress should update outdated privacy statutes to explicitly authorize privacy-preserving record linkage and cryptographic matching across federal programs. Secure, responsible data collaboration between agencies is foundational to detecting the organized fraud schemes that exploit multiple programs simultaneously.
Require integrity safeguards in emergency legislation. The pandemic demonstrated how quickly large sums can be stolen when emergency programs are deployed without basic protective infrastructure in place. Congress should establish mandatory fraud prevention standards and require them as a condition of any future emergency funding authorization.
Authorize pre-disbursement fraud holds. Congress should empower the Department of the Treasury to implement tiered, time-limited payment holds on high-risk disbursements, paired with expedited due process protections, allowing suspicious payments to be reviewed before funds are released.
Require public fraud risk reporting. Federal agencies should be required to conduct and publish annual fraud risk assessments identifying major program vulnerabilities, establish measurable prevention metrics, and report on the effectiveness of controls, not simply catalog detected fraud after the fact.
Reform budget scorekeeping for program integrity investments. Current CBO scorekeeping conventions treat investments in fraud prevention as spending increases without crediting the offsetting value of losses avoided. This causes proposals to expand program integrity initiatives to appear to worsen the deficit even when evidence suggests they yield net long-term savings. Agencies underinvest in fraud prevention technologies and tools as a result, costing taxpayers billions. Congress should direct updated scoring methodologies that treat documented program integrity savings as scoreable offsets.
The United States cannot prosecute its way out of this crisis. Reducing fraud at scale means redesigning public systems to be resilient against organized criminal exploitation from the outset. The Program Integrity Alliance stands ready to partner with policymakers across government to advance these reforms and restore integrity to federal programs.
About Us
The Program Integrity Alliance is an independent 501(c)(3) nonprofit, nonpartisan organization committed to strengthening public integrity through data, evidence, and innovation.