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.