2025 marked another notable year in State Attorneys General (AG) enforcement, with both a sharp uptick in multistate AG actions filed against the federal government and significant actions targeting the private sector across industries. We will highlight two issue areas here—antitrust and consumer protection—and describe the escalating friction between State AGs and the federal government as well as distill this year’s trends into actionable takeaways for businesses as we enter 2026.
Husch Blackwell has formally launched its Congressional Investigations practice to assist clients across industries with all types of congressional inquiries. Our bipartisan team includes seasoned trial lawyers with specific experience in congressional investigations, former senior staff from executive branch agencies well-versed in responding to congressional inquiries, and former senior staffers from congressional committees involved in
Todd Gee and I recently published an article in Risk Management, discussing in detail the growing risk of state-level False Claims Act (FCA) enforcement for state government contractors and recipients of state funds or benefits. While many government funding recipients are familiar with the federal FCA, state legislatures across the nation are either establishing—or
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.
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.