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The March 2020 Coronavirus Aid, Relief, and Economic Security
Act ("CARES Act") created enormous incentives for
companies to apply for economic stimulus funding and grants to
alleviate the devastating economic impacts from the worldwide
pandemic. Until recently, the U.S. Department of Justice
("DOJ") focused mainly on filing criminal actions against
individuals who allegedly committed fraud and made false statements
in connection with CARES Act stimulus funds, in particular criminal
fraud cases involving the Small Business Administration Paycheck
Protection Program ("PPP"). But a recent PPP enforcement