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Soon after Congress passed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in March 2020, the Criminal Division of the U.S. Department of Justice (DOJ) moved quickly to address potential COVID-19 related fraud. One area of early focus was the Paycheck Protection Program (PPP), a program under the CARES Act that provides loans to small businesses to help pay employees. The Fraud Section set up a team devoted to PPP fraud and, within two months of the passage of the CARES Act, had charged several individuals. Our client alert from May 2020 detailed the very first wave of PPP-related charges and offered several predictions for how such cases would unfold.[1] This update reviews recent developments in DOJ enforcement and provides new predictions for the future of COVID-19 relief fraud enforcement. In short, DOJ enforcement of PPP fraud remains in its early stages, still focused more on brazen acts of f