As the government revives its Paycheck Protection Program (PPP) with hundreds of billions of dollars in additional loans available to small businesses, there are fresh signs that government fraud investigations and whistleblower litigation related to the loan program are ramping up. DOJ’s first-ever settlement of violations of the civil False Claims Act related to the PPP highlight the scrutiny facing the PPP and risks for borrowers just as the PPP enters a new phase following the December 27, 2020, Economic Aid Act. This update provides an overview of the latest developments in fraud enforcement actions related to the PPP and key takeaways from the recent False Claims Act settlement.

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