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Wednesday, March 4, 2026

Iceberg Ahead! Top Massachusetts Federal Prosecutor Sounds the Alarm on the “Tip of the Iceberg” of PPP Fraud Prosecutions - Mintz

The Department of Justice (DOJ) and the U.S. Attorney’s Office for the District of Massachusetts are zeroing in on investigations and prosecutions involving fraud on government programs. U.S. Attorney Leah B. Foley has made clear that fraud prosecutions involving government programs are increasing, not slowing down, and the announcement of recent benefits-fraud cases are just “the tip of the iceberg.” Nationally, the White House has also announced a new DOJ division focused on fraud. For companies—particularly their boards and C-Suite executives—lenders, and individuals who pocketed COVID-19 relief money or other federal benefits, risk remains high, investigative tools are increasingly sophisticated, and early legal engagement is critical.

The New Enforcement Architecture: From Washington to Boston and Nationwide

The federal enforcement structure has significantly expanded, with the DOJ’s Criminal Fraud Section undergoing a major reorganization to protect taxpayer funds and prioritize prosecuting government program fraud. Increased government resources, advanced data analytics, and bipartisan support underscore this focus. Nationally, a new DOJ Fraud Enforcement Division is being established. The District of Massachusetts has emerged as a particularly active jurisdiction, with U.S. Attorney Foley appointing a fraud coordinator to enhance investigations, coordination, and enforcement strategies across federal and state enforcement agencies. Her public comments demonstrate...



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