Even though five years have passed since Congress enacted the Paycheck Protection Program (PPP) as an emergency response to the COVID‑19 pandemic, enforcement activity relating to PPP loans remains an active component of the federal government’s civil fraud agenda and—with the statute of limitations not expiring for another roughly five years—all indications are that it will continue to be an enforcement priority for the foreseeable future. While some of the more notable early pandemic enforcement actions were criminal prosecutions involving loan and forgiveness applications submitted by individuals claiming to operate companies that simply did not exist, there are a growing number of False Claims Act (FCA) suits against existing companies wherein the government or whistleblowers maintain that the companies allegedly were not eligible to receive the PPP funds.