In an effort to combat the devastating economic effects of the COVID-19 pandemic, Congress enacted the Coronavirus Aid, Relief, and Economic Security (CARES) Act, authorizing $2.2 trillion in relief—the largest stimulus package in American history. Unsurprisingly, given the magnitude of the package, the Government early on expressed a commitment to aggressively investigate and prosecute any fraud against the relief program. Beyond the scale of the expenditure, its exigency necessitated relaxed anti-fraud measures and de minimus oversight relating to distribution of funds—conditions that will keep both the Government and private relators (i.e., whistleblowers) busy over the next several years. One toolset likely to be relied upon in the coming years in connection with combatting CARES Act fraud will be data analytics and data mining.

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