Alerts9.30.25
DOJ Intensifies Enforcement Against Foreign-Affiliated Companies Over PPP Loan Certifications
Highlights
- The Department of Justice (DOJ) has increased scrutiny of foreign-affiliated companies that obtained Paycheck Protection Program (PPP) loans without properly accounting for global employee counts.
- Recent settlements show DOJ applying penalties of 1.5–2x the loan amount, reflecting heightened False Claims Act (FCA) enforcement risk.
- Qui tam whistleblower suits, fueled by public PPP data, are driving many of these cases and compounding exposure.
The U.S. DOJ has escalated its scrutiny of foreign-affiliated companies that received PPP loans by certifying compliance with employee count requirements, while neglecting to account for affiliation rules and their global workforce. This enforcement trend has emerged as a significant focus for the DOJ, with recent settlements underscoring the agency's commitment to addressing these compliance failures.
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