Melissa Brumer

Melissa Brumer

April 01, 2021 | New York Law Journal

For Civil Enforcement, the Pandemic Is Just Beginning

There have been many criminal prosecutions of COVID-related fraud—the DOJ recently announced that the Fraud Section has criminally charged at least 120 defendants to date in fraud cases involving the PPP—but those often alleged egregious misconduct. Two new end-of-year settlements go beyond such incidents of egregious wrongdoing, however, and shed greater light on how the government might pursue civil enforcement for companies whose behavior was grey, sloppy, or pushed boundaries, which William Harrington, Annie Railton and Melissa Brumer discuss in this Federal Civil Enforcement column.

By William Harrington, Annie Railton and Melissa Brumer

8 minute read