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DOJ Investigations of Fraud in PPP Loan Applications: False Claims Act, Corporate and Personal Liability

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, August 31, 2022

Recorded event now available

or call 1-800-926-7926

This CLE webinar will advise corporate counsel on the current Department of Justice (DOJ) investigations of fraud in Paycheck Protection Program (PPP) applications. The panel will address the potential criminal and civil enforcement actions against businesses and owners who fraudulently applied for and received these emergency loans.


The DOJ has started investigating and subsequently confirmed that the Paycheck Protection Program (PPP) was the subject of persistent fraud, possibly totaling $80 billion in fraudulent loans. Federal prosecutors call this theft of taxpayer money "the largest fraud in U.S. history" as it represents approximately 10 percent of the $800 billion handed out to small businesses during the pandemic.

During the DOJ's pursuit of PPP fraud prosecutions, the government may find it difficult to distinguish between borrowers that intended and affirmatively acted to commit fraud and those that were well-intentioned but failed to comply with the federal relief program. Many unwitting borrowers may find themselves caught in the DOJ's fishnet of fraud charges. Business owners who received PPP funds must immediately evaluate their compliance and potential exposure as the target of a federal investigation.

Listen as our expert panel discusses the government's process for identifying and investigating potential fraud and the status of PPP loan fraud prosecution. The panel will also provide best practices for responding to a Request for Information related to pandemic relief funds and what steps to mitigate noncompliance and address corrective measures before an investigation begins.



  1. Paycheck Protection Program
    1. History
    2. DOJ investigations
      1. Prior prosecutions
    3. Civil penalties
    4. Criminal penalties
    5. Mitigate noncompliance
  2. Other best practices


The panel will discuss these and other relevant topics:

  • How is the DOJ distinguishing between intentional fraud and poor business decision-making?
  • What are the potential civil and criminal penalties for PPP loan fraud?
  • What steps can businesses take to mitigate noncompliance and potential PPP loan fraud exposure?


DeWaard, Ronald
Ronald G. DeWaard


Mr. DeWaard is a trial lawyer and former federal prosecutor who currently serves as chair of the firm. He concentrates...  |  Read More

Mouw, Gary
Gary J. Mouw


Mr. Mouw's practice is primarily focused on representing companies and individuals – in Michigan and across...  |  Read More

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