A year after the COVID-19 pandemic hit the U.S., it remains to be seen how the Biden Administration will approach enforcement against businesses who received pandemic relief through the CARES Act and other federal spending packages. Nonetheless, patterns of enforcement related to pandemic assistance in 2020 may provide insight into potential enforcement trends in 2021. While initial cases have largely focused on small businesses that submitted fraudulent applications for relief funds (i.e. low-hanging fruit), these cases may set the stage for DOJ enforcement against larger companies.

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