As we noted in our recent civil update, the pace of criminal cases related to Paycheck Protection Program (PPP) loan fraud has not slowed. Here are a few significant cases from the last several months.
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.
On June 4, 2026, The United States Court of Appeals for the Fourth Circuit issued a decision affirming the dismissal of a False Claims Act (FCA) suit for failure to meet Rule 9(b)’s pleading requirements—i.e., failing to state with “particularity the circumstances constituting fraud or mistake.” The decision marks an important victory for FCA defendants faced with vague or imprecise allegations of wrongdoing.
On June 24, 2026, Acting Attorney General of the United States Todd Blanche along with other senior government officials and leaders announced “the greatest combined federal and state effort in combating healthcare fraud in history.” The 2026 National Health Care Fraud Takedown heralded 455 defendants charged across 56 federal districts and 45 states and territories, in connection with more than $6.5 billion in alleged false claims submitted to Medicare, Medicaid, and other federal health programs—all in a coordinated two-week window.
Earlier this month, the U.S. Supreme Court issued its 9-0 decision in Sripetch v. Securities and Exchange Commission, holding that the U.S. Securities and Exchange Commission (SEC) can retrieve ill-gotten gains from alleged securities-law violators without having to prove that victims of those violations suffered a pecuniary loss.[1] Sripetch is the most recent decision in a series of U.S. Supreme Court cases analyzing the SEC’s disgorgement powers.
On April 7, 2026, the Department of Justice (DOJ) announced it is “supercharging” fraud prosecutions through the creation of the National Fraud Enforcement Division (the “Fraud Division”).
On December 19, 2025 and January 30, 2026, the United States Sentencing Commission released proposed amendments to the Federal Sentencing Guidelines for 2026. See U.S. Sentencing Comm’n, Proposed 2026 Amendments to the Federal Sentencing Guidelines (Dec. 2025 and Jan. 2026). Taken together, these amendments suggest a meaningful recalibration of how federal sentences may be calculated and, for some defendants, an opportunity for more individualized and potentially less severe outcomes.
How AI-Powered Attacks, Supply Chain Vulnerabilities, and Regulatory Pressures Are Shaping Cybersecurity Today
In today’s digital-first world, cybersecurity has never been more crucial. Organizations across every industry face a rapidly changing threat landscape, with data breaches growing in frequency and sophistication. Modern attackers leverage advancements in technology, particularly artificial intelligence (AI), to launch innovative campaigns that challenge traditional defenses. At the same time, supply chain vulnerabilities and increased regulatory scrutiny are raising the stakes for organizations.
On March 10, 2026, the Department of Justice (DOJ) issued a new Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), which now governs all corporate criminal matters handled by DOJ except for antitrust violations. This new policy creates a single set of standards for voluntary self-disclosure, cooperation, and remediation across the Department.
Rebecca Furdek recently published an article in Wisconsin Lawyer magazine reviewing the first year of the second Trump administration. She discusses three primary trends: the use of executive orders, deregulation across federal agencies, and white-collar enforcement priorities. As Rebecca explains, “[t]he second Trump term started with a splash in both the federal regulatory and enforcement