Rear View Mirror: Criminal Exposure for Companies that Received PPP Loans Under the CARES Act

In response to complaints that large publicly-traded companies had received loans through the SBA's Paycheck Protection Program, Treasury Secretary Mnuchin announced that companies receiving loans of more than $2 million would be subjected to a full review before being forgiven, and that the Small Business Administration would audit the business when it applied for forgiveness “as appropriate,” to verify their earlier size, eligibility, and necessity certifications, with criminal consequences for fraud.