Bloomberg Publishes Article by Jennifer Serafyn, Teddie Arnold, and Christopher Robertson on Evolving PPP Enforcement

Bloomberg featured an article by partners Jennifer Serafyn, Teddie Arnold, and Christopher Robertson, “DOJ’s PPP Enforcement Is Evolving—Is Your Company Prepared Yet?” The piece, published on June 24, 2026, examines how the US Department of Justice is reshaping enforcement of Paycheck Protection Program (PPP) loans through more sophisticated, data-driven approaches.

The article highlights the DOJ’s emerging two-track enforcement model, combining curated whistleblower (qui tam) actions with government-initiated investigations powered by data analytics and interagency coordination. It also underscores a shift from traditional fraud cases to more complex eligibility-based claims, creating new and ongoing risk exposure for both borrowers and lenders—even after loan forgiveness.

The authors emphasize the increasing scope and sophistication of enforcement, noting:

“The DOJ’s newest enforcement initiative signals that PPP exposure isn’t winding down — it’s becoming more sophisticated, more data-driven, and harder to see coming.”

The full article is available here.