News & Analysis as of

Paycheck Protection Program (PPP) Enforcement Actions

Benesch

Paycheck Protection Program (“PPP”) Loan Fraud: A Survey & Analysis of Recent Civil & Criminal Enforcement Outcomes

Benesch on

The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal law enacted in or around March 2020 designed to provide emergency financial assistance to the millions of Americans who were suffering the...more

ArentFox Schiff

Investigations Newsletter: Home Health Care Company to Pay $3 Million to Resolve FCA Allegations

ArentFox Schiff on

Home Health Care Company to Pay $3 Million to Resolve FCA Allegations - The US Department of Justice (DOJ) announced that Saad Enterprises Incorporated, operating as Saad Healthcare, agreed to pay $3 million to resolve...more

Husch Blackwell LLP

Justice Department Files False Claims Act Complaint Against Home Health Agency Over PPP Loans

Husch Blackwell LLP on

On February 25, 2025, the U.S. Department of Justice filed a False Claims Act (FCA) complaint against an Idaho home health agency and its owner, alleging that a series of Paycheck Protection Program (PPP) loan applications...more

ArentFox Schiff

Investigations Newsletter: First Circuit Joins Sixth and Eighth Circuits in Adopting Heightened, But-For Causation Standard for...

ArentFox Schiff on

First Circuit Joins Sixth and Eighth Circuits in Adopting Heightened, But-For Causation Standard for AKS-Based FCA Claims - On February 18, the US Court of Appeals for the First Circuit became the latest court to agree...more

Ropes & Gray LLP

False Claims Act Insights: Key Takeaways from DOJ’s Fiscal Year 2024 Cases & Recoveries

Ropes & Gray LLP on

The U.S. Department of Justice (DOJ) announced last Wednesday that settlements and judgments under the False Claims Act (FCA) exceeded $2.9 billion in fiscal year 2024—up approximately 5% from last year. DOJ’s announcement...more

Wiley Rein LLP

DOJ Announces Larger FCA Recoveries and More Whistleblower Cases Filed in 2024

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On January 15, 2025, the U.S. Department of Justice (DOJ) announced $2.9 billion in total False Claims Act (FCA) recoveries for FY 2024, a slight increase from 2023. In addition to growing recoveries, DOJ announced a new...more

Mintz - Health Care Viewpoints

EnforceMintz — Long Tail of Pandemic Fraud Schemes Will Likely Result in Continued Enforcement for Years to Come

In last year’s edition of EnforceMintz, we predicted that 2024 would bring an increase in False Claims Act (FCA) enforcement activity related to COVID-19 pandemic fraud. Those predictions proved correct. The COVID-19 Fraud...more

Orrick, Herrington & Sutcliffe LLP

Paycheck Protection Program: Potential Liability Grows

Although the Paycheck Protection Program ended in 2021, PPP loan enforcement and litigation remain alive and well. Government and private actions during the past 12 months signal a continued focus on alleged fraud and...more

PilieroMazza PLLC

PPP Loans Under the Microscope: False Claims Act and Enforcement Trends

PilieroMazza PLLC on

While the COVID-19 pandemic may feel like a distant memory for many, its effects continue to reverberate for others—particularly for businesses that obtained loans through the Paycheck Protection Program (PPP). Whether...more

Cozen O'Connor

Whistleblower Watch - A quarterly update on FCA Enforcement and Qui Tam Litigation

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Whistleblower Watch is a critical resource for in-house counsel and compliance professionals. Each quarter, Cozen O’Connor summarizes the most notable False Claims Act (FCA) enforcement actions, settlements, and legal trends,...more

J.S. Held

Current Enforcement Efforts in the Battle Against COVID-19 Loan Program Fraud

J.S. Held on

The COVID-19 pandemic caused unprecedented impacts around the world including stay-at-home orders, curfews, quarantines, and economic uncertainty. Businesses across the United States were forced to close their doors, limit...more

Bass, Berry & Sims PLC

COVID-19 Relief Enforcement Actions Highlight Ongoing Risk

Bass, Berry & Sims PLC on

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....more

Foley Hoag LLP - White Collar Law &...

Health Care Fraud Enforcement in 2024

This is the ninth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year... The government had another busy year in 2023 investigating and prosecuting health...more

BakerHostetler

What’s the Damage? - The FTC Cracks Down on False Promises of PPP Loans

BakerHostetler on

Note: The March 25 version of this article has been updated. The other day, the FTC announced settlements with two different companies that allegedly made false promises to small businesses that their companies could help...more

Morgan Lewis

Paycheck Protection Program Enforcement Likely to Continue with Focus on More Complex Cases

Morgan Lewis on

Recent Paycheck Protection Program (PPP) enforcement trends suggest that the US Department of Justice (DOJ) has begun focusing on False Claims Act (FCA) enforcement actions centered on PPP applicants’ technical compliance...more

Dorsey & Whitney LLP

False Claims Act Settlements and Judgments Near $3 Billion in 2023

Dorsey & Whitney LLP on

The U.S. Department of Justice (DOJ) announced recently that settlements and judgments under the False Claims Act, 31 U.S.C. § 3729, et seq. (FCA) totaled approximately $2.7 billion in FY 2023 (October 1, 2022 – September 30,...more

Seyfarth Shaw LLP

DOJ False Claims Act Statistics Feature Record Numbers, Familiar Industries and New Initiatives for FY 2023

Seyfarth Shaw LLP on

On February 22, 2024, the Department of Justice (“DOJ”) reported its annual recoveries under the False Claims Act (“FCA” or “the Act”) for Fiscal Year (“FY”) 2023, in which it recovered more than $2.68 billion in settlements...more

K&L Gates LLP

US Department of Justice Announces US$2.68 Billion in Fiscal Year 2023 False Claims Act Recoveries

K&L Gates LLP on

On 22 February 2024, the US Department of Justice (DOJ) published its report (Report) announcing civil recoveries under the False Claims Act (FCA) for Fiscal Year (FY) 2023. The recoveries for FY 2023 exceeded US$2.68...more

Buchalter

PPP Fraud Enforcement Shows No Signs of Slowing

Buchalter on

After dozens of high-profile criminal prosecutions and a growing wave of civil investigations, the Department of Justice’s (“DOJ”) Covid-19 Fraud Enforcement Strike Force is poised to continue its pursuit of fraud, abuse, and...more

King & Spalding

DOJ Announces Results of Nationwide COVID-19 Fraud Enforcement Action, Launches Two New COVID-19 Fraud Strike Forces

King & Spalding on

On August 23, 2023, DOJ announced that its latest coordinated, nationwide enforcement action to combat COVID-19 relief fraud has resulted in 718 enforcement actions, including federal criminal charges against 371 defendants,...more

Orrick, Herrington & Sutcliffe LLP

DOJ Appears to Shift Focus to Lenders in Paycheck Protection Program Investigations: What You Need to Know

The Department of Justice appears to be shifting its focus from investigating fraudulent behavior by Paycheck Protection Program (PPP) borrowers to investigating lenders and related institutions....more

Burr & Forman

The USDOJ Continues to Increase Its Fraud Enforcement Actions Related To COVID-19 Relief Benefits

Burr & Forman on

Fraud enforcement actions by the United States Department of Justice (USDOJ) continue to rise against companies and individuals related to their applications for and receipt of COVID-19 benefits. It appears that no type of...more

K&L Gates LLP

Up Next: Lenders May Be the Next Government Focus for PPP Fraud

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INTRODUCTION - On 24 January 2023, the Board of Governors of the Federal Reserve System (the FRB) announced it entered into a consent order (Consent Order) with a member bank imposing an approximately US$2.3 million civil...more

Clark Hill PLC

US Department of Justice Expanding Prosecution of Individuals and Companies for Payroll Protection Program Fraud

Clark Hill PLC on

In May 2022, the US Department of Justice (US DOJ) filed its first civil complaint for Payroll Protection Program (PPP) fraud under the federal False Claims Act (FCA) in a Florida federal court. The government alleged that...more

Latham & Watkins LLP

US Government Uses Receipt of PPP Funds to Create Piggyback Liability in FCA Case

Latham & Watkins LLP on

Physician Partners of America’s settlement highlights significant risks facing False Claims Act defendants who received Paycheck Protection Program funds. An April 2022 US Department of Justice (DOJ) settlement suggests...more

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