Government Investigations

On August 29, 2025, the Department of Justice (DOJ) launched a new Trade Fraud Task Force, which will leverage resources from DOJ’s Civil and Criminal Divisions as well as the Department of Homeland Security (DHS) to enforce tariff and duties evasion, smuggling, and other import violations. The initiative furthers the Trump Administration’s “America First Trade Policy” announced on Inauguration Day and in Executive Order 14243, which promotes information-sharing between agencies to support the administration’s overall goals of combating waste, fraud, and abuse.

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.

When companies receive their first 2703(d) order from law enforcement, their response is usually a mix of confusion and terror. In the ever-evolving landscape of digital communications, understanding the legal mechanisms that govern data access is crucial. One such mechanism is the 2703(d) order, a powerful tool that law enforcement is using more and more as digital evidence becomes more robust and complex. This post examines the nature of a 2703(d) order and considers its implications for organizations, privacy officers, compliance professionals, and defense counsel.