We recently co-authored an article for The Banking Law Journal about the Department of Justice’s (DOJ) ongoing efforts to target businesses it alleges to have fraudulently received COVID-19 relief funds.

We said the enforcement efforts, both criminal and civil, have spanned industries, but both fintech and healthcare have been a particular focus of these actions in the past three years.

“But irrespective of industry, companies defending these matters should consider whether DOJ actually has a viable fraud case given that the alleged misconduct occurred in an uncertain regulatory landscape,” we explained in the article. “These fraud statutes, whether in the civil or criminal context, are intended to penalize bad actors that engaged in fraud, not companies that acted in good faith and made a mistake in understanding relevant guidance.”

The full article, “COVID-19 Relief Lending Faces Scrutiny,” was published by The Banking Law Journal in the February 2025 edition and is available here.