COVID-19 Relief Enforcement Actions Highlight Ongoing Risk

The Department of Justice (DOJ) continues to demonstrate its sustained interest in COVID-19 relief fraud as an enforcement priority and we can expect to see persistent enforcement in this area.

We've previously covered how the Coronavirus Aid, Relief, and Economic Security (CARES) Act created a perfect storm for enforcement: the government quickly provided trillions of dollars of aid, imposed limited conditions before distributing funds, and offered changing guidance on how monies were to be used.

To date, pandemic-related fraud cases and investigations have generally involved allegations regarding an individual's or a company's eligibility (or ineligibility) for a Paycheck Protection Program (PPP) loan under the relevant framework or false certifications related to a company's application. And, the government is continuing its efforts along those lines. For example, on March 30, the United States elected to intervene in a qui tam complaint filed in the Central