Recipients of CARES Act funds must guard against the oncoming wave of enforcement actions. Making misrepresentations to the government when receiving relief funds may lead to severe criminal and/or civil liability. To minimize these risk, businesses should stay informed about regulatory developments related to COVID-19 and carefully review all conditions of payment before requesting and using government funds. They should also maintain strong compliance programs to ensure employees understand these legal requirements to mitigate risks, but also be prepared to promptly respond to allegations of fraud, waste, or abuse.

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