On April 20, 2023, the Department of Justice announced criminal charges against 18 defendants in nine federal districts, alleging over $490 million in alleged theft from federally funded COVID-19 relief programs. This clearly shows that, even as the COVID-19 pandemic continues to recede into the national memory—evidenced by the recent culmination of the national emergency

With some estimates as high as $80 billion, fraud within the Small Business Administration’s Paycheck Protection Program (PPP) has been described as the worst in a generation. The government has taken note with aggressive enforcement strategies across the country. Starting with what can be described as low-hanging fruit, the government’s enforcement efforts have expanded and