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The New Face of COVID-19 Fraud Enforcement: An Inter-Agency Task Force

On May 17, 2021, Attorney General Merrick Garland announced a new, inter-agency task force led by Deputy Attorney General Lisa Monaco to address fraud related to the COVID-19 pandemic (COVID-19 Task Force). According to DOJ’s...more

Five Developments Identified in Criminal and Civil Enforcement of PPP Loans

Recently, the Beverly Hills Bar Association in California sponsored a panel presentation on “PPP Enforcement Trends,” whose panelists included a high-level prosecutor from the United States Attorney’s Office and other leading...more

FinCEN Advisory and Notice on Financial Crimes Targeting COVID-19 Economic Impact Payments

On February 24, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions to the potential for fraud and other financial crimes related to Economic Impact Payments (EIPs) and a...more

New SBA PPP Loan Necessity Questionnaire Is Available Prior To OMB Approval: Are Lenders Jumping the Gun?

On October 26, 2020, the Small Business Administration (SBA) published notice in the federal register that it is seeking approval from the government’s Office of Management and Budget (OMB) to release two new forms (Form 3509...more

FinCEN Issues Advisory on Cybercrime and Cyber-Enabled Crime Exploiting COVID-19

On July 30, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions to potential indicators of cybercrime and cyber-enabled crime observed during the COVID-19 pandemic.The...more

A Review of Recent Whistleblower Developments - August 2020

Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: SEC...more

Top 10 Insights from the SBA’s PPP Loan Forgiveness Application

On May 15, 2020, the SBA issued its Paycheck Protection Program (PPP) Loan Forgiveness Application. 1. Permits Use of Alternative Payroll Covered Period - While the term of the “Covered Period” for loan forgiveness...more

Accepting CARES Act Assistance: Congressional and Other Investigative Risks

While recent federal funding has provided a lifeline for some companies, accepting government assistance under the CARES Act also carries significant legal, political and reputational risks for recipients. Loans are the tip...more

Applying for a CARES Act Loan? Take Three Simple Steps Now to Avoid Government Scrutiny Later (Updated May 6, 2020)

Businesses that applied for a Small Business Administration’s (SBA) Paycheck Protection Program (PPP) loan have a chance to change their minds if they return the money by May 14, 2020. With the onslaught of COVID-19...more

Applying for a CARES Act Loan? Take Three Simple Steps Now to Avoid Government Scrutiny Later (Update May 4, 2020)

Businesses that applied for a Small Business Administration’s (SBA) Paycheck Protection Program (PPP) loan have a chance to change their minds if they return the money by May 7, 2020. With the onslaught of COVID-19...more

Applying for a CARES Act Loan? Take Three Simple Steps Now to Avoid Government Scrutiny Later

With the onslaught of COVID-19 business closures, the government invited businesses around the country to apply for CARES Act relief to help survive the closures. Many have chosen to apply for assistance through the Small...more

Anti-Fraud Enforcement in the Coronavirus Era

In times of crisis, there are heroes, villains, victims, and everyone in between. Amidst the COVID-19 crisis, many valiant efforts are under immense time pressure—to care for the ill, to protect the vulnerable, to find and...more

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