The U.S. Department of Justice (DOJ) continues to treat Paycheck Protection Program (PPP) loan fraud as an enforcement priority. As we have noted in prior updates covering both criminal and civil enforcement, the pace of new cases has not slowed. Below is an overview of significant PPP-related civil enforcement actions from late 2025 through July 2026. In the coming days, we will post a second blog with an update on criminal enforcement.
In August 2025, the U.S. Department of Justice (DOJ) declined to prosecute an insurance company for alleged violations of the Foreign Corrupt Practices Act (FCPA), marking the first action of its kind since the DOJ paused FCPA prosecutions earlier this year. DOJ’s decision came in response to the company’s voluntary self-disclosure. Importantly, this decision allows the company to avoid criminal charges in connection with bribes allegedly paid by employees of its foreign subsidiary for customer referrals for products. As part of the resolution with DOJ, the company will disgorge approximately $4.7 million in profits that are tied to the misconduct.