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ARTICLE · 11 MARCH 2025

Recent Deluge Of Paycheck Protection Program False Claims Act Settlements

Crowell & Moring LLP
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United States Attorneys' Offices recently announced a number of False Claims Act (FCA) settlements arising out of the Paycheck Protection Program (PPP). These settlements reveal several trends that PPP loan.

United StatesLitigation, Mediation & Arbitration
Jason M. Crawford
Jason M. Crawford
Olivia Lynch
Olivia Lynch
Amy Laderberg O'Sullivan
Amy Laderberg O'Sullivan
Agustin D. Orozco
Agustin D. Orozco
Zachary Schroeder
Zachary Schroeder

United States Attorneys' Offices recently announced a number of False Claims Act (FCA) settlements arising out of the Paycheck Protection Program (PPP). These settlements reveal several trends that PPP loan recipients should be aware of.

First, the settlements were driven by qui tam suits filed by serial relator, GNGH2. We have previously reported on settlements obtained by GNGH2 as well as other serial relators, such as Relator LLC. These relators have relied on PPP data published by the Small Business Administration (SBA) and other publicly available data to craft allegations that borrowers have violated the FCA by seeking PPP loans for which they were ineligible.

Second, the Department of Justice (DOJ) elected to intervene in these cases. While we previously reported how the U.S. District Court for the Eastern District of California's dismissal of a Relator LLC qui tam complaint for failure to overcome the FCA's public disclosure bar was a welcome development

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