The Coronavirus Aid, Relief, and Economic Security
("CARES") Act provides $2.2 trillion of government funds
to combat the effects of the COVID-19 pandemic.
The financial assistance available to impacted companies comes
in various forms, including loans, loan guarantees, grants, direct
rebates, and other tax relief1. The potential for
fraud and abuse involving large government programs is high,
particularly those that are new and evolved from a crises situation
like the COVID-19 pandemic. Companies taking advantage of
CARES Act funding will therefore be subject to heightened scrutiny,
including with respect to their compliance with the False Claims
Act ("FCA"), which imposes liability on any person who
knowingly submits a false claim to the government or causes another
to submit a false claim to the government or knowingly makes a
false record or statement in order to have a false claim paid by
the government. 31 U.S.C. § 3729 et seq.
