COVID-19 Oversight and Enforcement

On September 9, 2021, President Biden signed an Executive Order (EO) to implement COVID safety protocols for Federal service contractors. While the EO did not identify specific safety protocols, it did direct a Federal task force (the “Safer Federal Workforce Task Force,” created by Executive Order in January 2021) to issue COVID-19-related workplace safety guidance

The U.S. government has prioritized oversight and enforcement of cases related to the COVID-19 pandemic. Sheppard Mullin’s COVID-19 Oversight & Enforcement Response Team is tracking new federal enforcement actions related to the COVID-19 in areas including fraud under the Coronavirus Aid, Relief, and Economic Stability Act (CARES Act) and Paycheck Protection Program (PPP), hoarding and

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.

Sheppard Mullin’s COVID-19 Oversight and Enforcement Response Team has tracked civil and criminal federal enforcement actions around the country since the passage of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) in March 2020. New cases are noted in our COVID-19 Enforcement Actions Tracker. These cases illustrate the federal government’s interest

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

Sheppard Mullin’s COVID-19 Oversight & Enforcement Response Team is dedicated to helping clients navigate the multi-faceted scrutiny resulting from the government’s Coronavirus Aid, Relief and Economic Stability Act (CARES Act) and Paycheck Protection Program (PPP) oversight and enforcement. Our team draws on our experience with agency oversight, investigations, and enforcement actions to help our clients

With the Department of Justice’s (DOJ) decision to drop charges against Michael Flynn, materiality has come to the forefront of popular legal discourse. At the same time, prosecutors and whistleblowers will carefully consider enforcement/false claims actions against entities who may have wrongfully received relief funds under the Coronavirus Aid, Recovery, and Economic Stability Act (CARES

The Paycheck Protection Program (PPP) provides a glimmer of hope to small businesses struggling to survive the COVID-19 pandemic, providing hundreds of billions in funding to assist small businesses impacted by the pandemic. The U.S. Small Business Administration (SBA) loan programs, including the PPP under the CARES Act, are only available to qualifying businesses that

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

The federal government has rolled out trillions of dollars in aid through the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). As past is often prologue, we expect this new round of massive government spending to someday be subjected to strict government oversight, audits and investigations, and whistleblowers searching for potential fraud, waste and