The Paycheck Protection Program (PPP) was intended to provide a fast influx of assistance to small businesses during the economic shock created by the COVID-19 pandemic. The speed with which loans were distributed to businesses nationwide was striking, and so was the speed with which the Department of Justice (DOJ) began prosecuting those abusing the program. Reports of corporations and individuals seeking to take advantage of the PPP prompted a vigorous law enforcement response that has broadened its scope in recent months. As we highlighted last year, the DOJ has taken aggressive action to pursue those who engaged in misconduct involving the PPP and other CARES Act stimulus programs.
In the beginning, the cases connected to COVID-19 stimulus programs—charging crimes such as bank fraud, false statements to a financial institution, and money laundering—involved brazen conduct, including the misuse of loan proceeds to buy things like luxury cars, homes, or jewelry. Now, we are seeing a significant increase in civil enforcement actions relating to the program. This increase signals a new phase of enforcement for the DOJ, and all organizations that benefited from the program must pay close attention.
Paycheck Protection Program
Congress enacted the PPP on March 29, 2020, as part of the CARES Act, to provide emergency financial support to millions of Americans suffering the economic effects caused by the COVID-19 pandemic. Under the PPP, eligible businesses could obtain loans...
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