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Kyle Gilster

When clients seek to resolve state or national governmental issues, they look to Kyle for smart guidance that advances their business objectives. Kyle’s practice involves governmental affairs, regulatory work, campaign finance, government contracts and election law. He works extensively with legislation related to banks, insurance, brokerage companies and trade finance. He also advises industry representatives from groups, companies and associations with legal services across the public policy spectrum, and he works on government affairs issues related to Health and Human Services and Centers for Medicare and Medicaid.

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During the first eight months of 2025, our team has paid close attention to the Trump administration’s strategy for civil and criminal enforcement concerning fraud related to Paycheck Protection Program (PPP) loans. In April, Jonathan Porter and Robert Peabody discussed the Department of Justice’s use of the False Claims Act (FCA)—a civil enforcement tool—to enforce potentially criminal COVID-related fraud. In May, Rebecca Furdek, Kyle Gilster, and Emily Loftis explained the framework for ongoing PPP loan audits and investigations, followed in August by a mid-year update regarding enforcement trends and notable cases.

These and other thought leadership pieces address the origination of the PPP loan landscape during COVID-19; the rise of audits, investigations, and enforcement actions through which these and similar loans have been scrutinized; and the basic elements of the civil and criminal enforcement frameworks used to prosecute fraudulent conduct in connection with these loans.

This post explores the federal government’s ongoing efforts to combat PPP-related fraud, focusing on emerging civil enforcement trends and theories of liability under the False Claims Act.

gavel on a money

Over the course of 2025, the Husch Blackwell Thought Leadership team has closely tracked the Trump administration’s evolving approach to enforcing fraud related to Paycheck Protection Program (PPP) loans. While our companion articles have detailed the latest trends in civil enforcement, including the Department of Justice’s (DOJ) use of the FCA and the role of whistleblowers, this post focuses on the rapidly developing landscape of criminal enforcement. In this article, we analyze recent DOJ charging theories, high-profile prosecutions, and the key risks facing both individuals and entities in the PPP fraud context.

Introduction

The regulatory landscape for cryptocurrencies and digital assets in the United States is undergoing significant changes with developments at the executive, agency, and legislative levels. The presidential administration promised change, guidance, and clarity to promote innovation and dominance in digital asset markets. This post examines the current state of crypto regulation in America, as well as what businesses and investors can expect in the near future.