GAO-25-107746 — COVID-19 Relief: Consequences of Fraud and Lessons for Prevention (April 9, 2025)

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A Q&A report to congressional committees by the U.S. Government Accountability Office, GAO-25-107746, COVID-19 Relief: Consequences of Fraud and Lessons for Prevention, dated April 9, 2025. It reports that 48 agencies distributed .5 trillion in pandemic response and estimates unemployment insurance fraud of between billion and billion from April 2020 through May 2023. It states the Small Business Administration's Office of Inspector General reported billion in Paycheck Protection Program and billion in COVID-19 EIDL potentially fraudulent loans as of June 2023. It reports at least 3,096 defendants charged and at least 2,532 found guilty as of December 31, 2024, and more than 650 civil settlements and judgments totaling more than million. It also describes False Claims Act actions, asset forfeiture, and recommendations to extend statutes of limitations to 10 years.

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GAO-25-107746 COVID-19 Relief 
 
Pandemic-relief programs were critical for assuring public health and economic 
stability. However, they also created unprecedented opportunities for fraud due 
to the dollars involved and other risk factors. These factors included changes to 
controls (e.g., reliance on self-certification) and the introduction of new programs.  
Considering what was likely lost to fraud during the pandemic and assessing 
what lessons and insights can be taken to better prepare for both normal 
operations and future emergencies is critical for agencies. Beyond financial 
impacts, fraud erodes public trust in government and hinders agencies’ efforts to 
execute their missions and program objectives effectively and efficiently. 
Therefore, taking steps to prevent fraud from occurring is crucial. 
While the disbursement of pandemic-relief funds is largely over, the work of 
investigating, prosecuting, and recovering fraudulently disbursed funds is 
ongoing. The Department of Justice (DOJ) and its law enforcement partners 
continue to prioritize the investigation and prosecution of defendants (individuals 
or entities) that committed these offenses.  
We performed this work under the CARES Act that includes a provision for GAO 
to report on our ongoing monitoring and oversight efforts related to the COVID-19 
pandemic. This report provides information on the status of pandemic-relief 
program cases involving fraud-related charges brought by DOJ and how 
agencies can enhance fraud prevention. 
 
 
 
• 
The full extent of pandemic-relief program fraud will likely never be known 
with certainty. However, estimates indicate that hundreds of billions of dollars 
in potentially fraudulent payments were disbursed. 
• 
At least 2,532 defendants have been found guilty of fraud-related charges 
involving pandemic-relief programs, as of December 31, 2024. Those 
sentenced faced serious consequences, including prison time and restitution 
orders. 
• 
Pandemic-relief program fraud was committed by individuals from all types of 
backgrounds. Although crime syndicates and career criminals were involved 
in some cases, many individuals who did not appear linked to organized fraud 
or criminal groups also defrauded these programs. 
• 
While agencies may never be able to sway all fraudsters from attempting to 
defraud programs, actions—such as establishing adequate controls and 
emphasizing the consequences of fraud—can be taken to prevent and deter 
future fraudsters. We have made numerous recommendations to help 
agencies effectively manage fraud risks.  
 
 
 
 
U.S. Government Accountability Office 
COVID-19 Relief: Consequences of Fraud and 
Lessons for Prevention 
GAO-25-107746  
Q&A Report to Congressional Committees 
April 9, 2025 
Why This Matters 
Key Takeaways 

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GAO-25-107746 COVID-19 Relief 
 
The full extent of fraud within the pandemic-relief programs will never be known 
with certainty. The scope of the pandemic-relief response; the inherently 
deceptive nature of fraudulent activities; and the resources needed for detection, 
investigation, and prosecution of fraud make it difficult to measure. However, 
estimates indicate hundreds of billions of dollars in potentially fraudulent 
payments were disbursed.  
Pandemic-relief programs were critical for assuring public health and economic 
stability. However, they also created unprecedented opportunities for fraud due 
to the dollars involved, among other risk factors. Forty-eight agencies distributed 
$4.5 trillion in response to the pandemic. Estimates of fraud exist for three of the 
more commonly defrauded pandemic-relief programs—the Department of 
Labor’s (DOL) Unemployment Insurance (UI) programs and the Small Business 
Administration’s (SBA) Paycheck Protection Program (PPP) and the COVID-19 
Economic Injury Disaster Loan (COVID-19 EIDL) program. Specifically,  
• 
in September 2023, we estimated that the fraud in DOL’s UI programs during 
the pandemic—from April 2020 through May 2023—was likely between $100 
billion and $135 billion;1 and  
• 
while there are no estimates of total fraud in PPP and COVID-19 EIDL 
payments, SBA’s Office of Inspector General (OIG) reported that, as of June 
2023, SBA had disbursed $64 billion from the PPP and $136 billion from the 
COVID-19 EIDL program in potentially fraudulent pandemic-relief loans.2 
In addition, our analysis of DOJ’s public statements on fraud-related cases 
showed that at least 19 different pandemic-relief programs have been defrauded, 
as of December 31, 2024 (see fig. 1).  
What is the extent of 
pandemic-relief fraud?  

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GAO-25-107746 COVID-19 Relief 
Figure 1: Federal Pandemic-Relief Programs That Were Defrauded, as of December 31, 2024  
 
Note: This figure does not include all defrauded federal pandemic-relief programs, such as state or local 
programs funded by CARES Act grants. In addition, there are cases pursued outside of the Department of 
Justice that may not be included in our data. We use the term pandemic-relief programs to refer to the 
programs and assistance outlined in six laws to help the nation respond to, and recover from, the COVID-19 
pandemic. Also, the Department of Agriculture’s child nutrition programs refer to two permanent programs—the 
Child and Adult Care Food Program and the Summer Food Service Program—that received COVID-19-era 
flexibilities. In addition, individuals and entities often defrauded multiple pandemic-relief programs, so the 
numbers presented above include instances of overlap between the programs.  
According to our analysis, the most commonly defrauded pandemic-relief 
programs were SBA’s PPP and the COVID-19 EIDL program, along with DOL’s 
UI programs. At least 2,393 defendants (or almost 95 percent) that have been 
found guilty of fraud-related charges involving pandemic-relief programs 
defrauded PPP, COVID-19 EIDL, and UI programs, either exclusively or in 
combination with each other or other pandemic-relief programs. See figure 2 for 
a breakdown of the 2,532 defendants that have been found guilty of fraud-related 
charges involving one or more pandemic-relief programs, as of December 31, 
2024.   
 
 

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GAO-25-107746 COVID-19 Relief 
Figure 2: Number of Defendants That Have Been Found Guilty of Fraud-Related Charges 
Involving Pandemic-Relief Programs, as of December 31, 2024
 
Note: The figure above includes defendants who either pleaded guilty or were convicted at trial. Some of these 
defendants have been sentenced, and some were awaiting sentencing, as of December 31, 2024. 
aProgram totals reflect instances where defendants defrauded that program either exclusively; along with PPP, 
COVID-19 EIDL, and UI programs; or in combination with other pandemic-relief programs. Therefore, to avoid 
double counting, this total does not reflect the sum of the individual program totals. 
 
As of December 31, 2024, DOJ has publicly announced criminal fraud-related 
charges involving pandemic-relief programs against at least 3,096 defendants—
which can be individuals or entities (see fig. 3). 
What is the status of 
DOJ’s criminal 
prosecution efforts 
against pandemic-relief 
fraudsters? 

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GAO-25-107746 COVID-19 Relief 
Figure 3: Number of Defendants Charged with Criminal Fraud-Related Offenses Involving 
Pandemic-Relief Programs and Case Status, as of December 31, 2024 
 
Note: Of the 2,532 defendants found guilty, 2,415 entered guilty pleas, and 117 were convicted at trial.  
We analyzed criminal cases identified from DOJ’s public statements and court 
documentation from March 2020 through December 2024. Out of the at least 
3,096 defendants charged with criminal fraud-related offenses involving 
pandemic-relief programs that have been publicly announced, 2,532 defendants 
(or almost 82 percent) have been found guilty.  
The number of defendants facing criminal fraud-related charges involving 
pandemic-relief programs continues to increase, as it takes time for new cases to 
be identified and developed, and hundreds of investigations are still underway. 
Additionally, extensions to statutes of limitations may contribute to an increase in 
cases. For example: 
• 
As of August 2022, the statute of limitations has been extended to 10 years to 
prosecute individuals who committed PPP and COVID-19 EIDL-related 
fraud.3  
• 
The multiagency COVID-19 Fraud Enforcement Task Force, which operates 
through DOJ, has recommended extending the statute of limitations for all 
criminal offenses affecting pandemic-relief funding, as well as for civil False 
Claims Act and Administrative False Claims Act violations.  
• 
DOL’s OIG and the Internal Revenue Service have requested that Congress 
extend the statute of limitations for the pandemic-relief UI and the Employee 
Retention Credit programs.  
• 
In January 2025, Congress introduced legislation that would extend the 
statute of limitations for violations relating to pandemic UI programs and other 
pandemic-relief programs to 10 years.4 
GAO supports such extensions, which would give our oversight partners and 
federal law enforcement additional time to investigate and pursue fraudulently 
obtained payments in these programs.5  

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GAO-25-107746 COVID-19 Relief 
 
No. Although criminal prosecutions serve as a key tool in the mission to address 
pandemic-relief program fraud and recover stolen funds, civil actions offer the 
government alternative ways to uncover more fraud schemes and recover funds. 
These civil actions include actions under the False Claims Act (FCA)—many of 
which are qui tams—and other civil remedies.6 See table 1 for more information 
on the FCA.  
Table 1: Overview of the False Claims Act (FCA) 
What is the FCA? 
• The FCA is a civil statute that makes individuals who knowingly submit false or 
fraudulent claims for payment to the government liable for three times the amount of 
damages which the government sustains, in addition to civil monetary penalties.a  
Who is involved? 
• FCA actions can be initiated by the Department of Justice (DOJ) or by private 
persons with knowledge of fraud (known as whistleblowers) who can bring suit on 
behalf of the government (called “qui tam” suits). 
How does it work? 
• DOJ can join—commonly described as intervene—in whistleblower-initiated actions.  
• The whistleblowers are also known as qui tam relators and are entitled to a 
portion—usually between 15 percent and 30 percent—of the recovered funds. 
When can claims 
be filed? 
• In general, FCA claims must be brought within 6 years of the date on which the 
violation occurred. 
Why is the FCA 
useful? 
• Civil statutes, including the FCA, have a lower burden of proof than criminal 
offenses. These statutes, according to DOJ officials, are a useful tool in fraud cases 
that might otherwise go unaddressed. 
• In addition, FCA whistleblower-initiated actions can provide details and help identify 
complex fraud schemes that would otherwise remain hidden. According to DOJ 
officials, many of its fraud investigations and lawsuits arise from qui tam actions. 
Source: GAO analysis of the False Claims Act.  |  GAO-25-107746 
a31 U.S.C §§ 3729-3733. FCA liability can also arise in other situations, such as when someone knowingly 
makes or uses, or causes to be made or used, a false record or statement material to a false claim or 
improperly avoids an obligation to pay the government. 
According to DOJ, from March 2020 to December 31, 2024, it has secured more 
than 650 civil settlements and judgments, totaling more than $500 million, to 
resolve allegations of fraud or overpayments in connection with the pandemic-
relief programs.7 Of the 112 publicly announced closed civil actions—settlements 
and judgments—that we reviewed related to pandemic-relief program fraud, we 
identified 58 as FCA actions initiated by whistleblowers.    
Pandemic-relief program fraud cases under the FCA have increased year-over-
year since the beginning of the pandemic in 2020 as cases are investigated and 
adjudicated. According to DOJ, that trend is expected to increase for the 
foreseeable future. DOJ recommends the extension of the FCA statute of 
limitations to 10 years to allow the government continued access to one of its 
primary antifraud and recovery tools.  
In addition, DOJ uses asset forfeiture as a tool to recover funds and assets lost 
to fraud through three different actions. 
Civil administrative: an action that permits personal property to be forfeited to 
the U.S. without filing a case in federal court, when no one contests the seizure 
of the property. Such seizure must be based on probable cause. A criminal 
conviction is not required for this action. 
Civil judicial: a court proceeding brought against property that was derived from, 
or used to commit, an offense, rather than against a person who committed an 
offense. A criminal conviction is not required for this proceeding. Property owners 
do not have to be charged, arrested, or convicted of any crime, but the 
government must present a preponderance of evidence that the property in 
question is legally forfeitable. 
Has DOJ used only 
criminal charges to 
prosecute pandemic-
relief program fraud? 

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GAO-25-107746 COVID-19 Relief 
Criminal forfeiture: an action against a defendant that includes notice of the 
intent to forfeit property in a criminal indictment. A conviction is required for this 
action.  
 
In addition to more traditional and organized criminal groups, entities in a wide 
variety of sectors, and individuals from all walks of life, defrauded pandemic-relief 
programs.  
Our review of DOJ’s public statements illustrated the different types of fraud 
schemes and fraudsters who attempted to defraud pandemic-relief programs. 
According to DOJ officials, in addition to the opportunistic fraud discussed below, 
domestic and transnational organized fraud groups are likely committing large-
scale fraud of pandemic-relief programs.8 DOJ is utilizing data analytics to 
investigate the fraud committed by these groups. 
Although crime syndicates and career criminals were involved in perpetrating 
fraud against pandemic-relief programs, a significant number of entities and 
individuals who did not appear linked to organized criminal groups also 
attempted to take advantage of these programs. These entities and individuals 
may be considered opportunists.  
According to the Association of Certified Fraud Examiners, opportunistic fraud 
typically happens when ordinarily honest people exploit a sudden and 
unexpected chance to defraud.9 As discussed later in this report, the pandemic 
created an environment for fraudsters to take advantage of disruptions in normal 
business operations, such as potentially weakened control environments. In turn, 
opportunistic fraud was prevalent during the pandemic.   
Our analysis showed that many types of opportunists attempted to defraud 
pandemic-relief programs (see fig. 4).  
 
 
Who defrauded the 
pandemic-relief 
programs? 

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GAO-25-107746 COVID-19 Relief 
Figure 4: Types of Opportunists GAO Identified in Pandemic-Relief Program Fraud Cases 
 
Note: This list is not inclusive of all the types of opportunists who defrauded pandemic-relief programs.  
In addition to the types of individual opportunists shown in figure 4, we identified 
cases where financial institutions and other entities entered into settlements to 
resolve allegations related to pandemic-relief programs, as discussed later in this 
report.  
 
Defendants found guilty of pandemic-related criminal fraud charges have been 
typically sentenced to prison time and ordered to pay restitution. Their sentencing  
varied based on the circumstances of the offense, as well as other factors, such 
as prior convictions and the presence of additional charges beyond fraud.  
Sentences ranged from probation to varying prison terms, followed by supervised 
release, with more than 80 percent of defendants sentenced to serve time in 
prison. In addition to prison time and probation, sentences included community 
service; fines; and, in a vast majority of cases, restitution.   
Prison sentences. Of the 2,143 defendants that were found guilty of fraud-
related charges involving pandemic-relief programs and sentenced as of 
December 31, 2024, 1,741 (81 percent) received prison time. Prison sentences 
ranged from 1 day to 30 years, with the majority of sentences between 1 and 5 
years. Figure 5 presents the different lengths of prison sentences. 
What consequences 
have pandemic-relief 
fraudsters faced in 
criminal court? 

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GAO-25-107746 COVID-19 Relief 
Figure 5: Prison Sentences for Defendants Found Guilty of Fraud-Related Charges Involving 
Pandemic-Relief Programs, as of December 31, 2024  
 
Note: Our analysis is limited to cases identified from the Department of Justice’s (DOJ) public statements and 
court documentation from March 2020 through December 31, 2024, and may not include all criminal fraud-
related charges involving pandemic-relief programs by DOJ. 
Restitution. Of the 2,143 defendants that were found guilty of fraud-related 
charges involving pandemic-relief programs and sentenced as of December 31, 
2024, 2,008 (or 94 percent) were ordered to pay restitution. Restitution amounts 
for those 2,008 defendants ranged, with the highest amount being over $71 
million. Over 440 defendants were ordered to pay $1 million or more in restitution 
each. See figure 6 for more information on the amount of restitution defendants 
have been ordered to repay. 
Figure 6: Court-Ordered Restitution for Defendants Found Guilty of Fraud-Related Charges 
Involving Pandemic-Relief Programs, as of December 31, 2024 
 
Note: Our analysis is limited to cases identified from the Department of Justice’s (DOJ) public statements and 
court documentation from March 2020 through December 31, 2024, and may not include all criminal fraud-
related charges involving pandemic-relief programs by DOJ. 
 
The majority of civil actions against pandemic-relief fraudsters resulted in 
settlements in which both parties agreed on a monetary payment that resolved 
allegations against the defendant, with or without admission of liability. 
Settlement amounts can include restitution; penalties; and other stipulations, 
such as attorney fees and accrued interest.  
The first pandemic-relief program fraud FCA whistleblower case settled in August 
2021. In this case, the defendant—the owner of a jet charter limited liability 
company—agreed to pay $287,055 to resolve allegations that he 
misappropriated $98,929 of PPP loan funds to pay for personal, noncompany-
What consequences 
have pandemic-relief 
fraudsters faced in civil 
court?  

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GAO-25-107746 COVID-19 Relief 
related expenses. Since then, judicial districts have reported settlements that 
have ranged from $11,665 to over $63 million.  
Two of the largest FCA whistleblower settlements to date occurred in 2024 and 
involved a single, now bankrupt lender. In May 2024, the lender agreed to 
provide the U.S. with a bankruptcy claim for recovery of up to $120 million to 
resolve allegations that it systemically inflated tens of thousands of PPP loans. In 
addition, the settlements resolved allegations that this lender knowingly failed to 
implement appropriate fraud controls to comply with PPP lender requirements. In 
particular, the U.S. alleged that the lender removed underwriting steps from its 
standard procedures to process a greater number of PPP loan applications and 
maximize processing fees.  
The vast majority of the 105 publicly announced settlements involve actions 
against SBA’s PPP or COVID-19 EIDL program, but there have been settlements 
involving other pandemic-relief programs (see fig. 7).  
Figure 7: Examples of Settlements Involving Pandemic-Relief Programs  
 
Individuals who defrauded pandemic-relief programs have experienced a variety 
of consequences. As described above, criminal court outcomes ranged from 
probation to prison time and generally included monetary penalties, such as 
restitution, fines, or assessment fees. See figure 8 for examples of the 
consequences imposed on pandemic-relief fraudsters.  
What are some specific 
consequences imposed 
on pandemic-relief 
fraudsters?     

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GAO-25-107746 COVID-19 Relief 
Figure 8: Examples of Consequences Imposed on Pandemic-Relief Fraudsters       
 
While the disbursement of pandemic-relief funds is largely over, DOJ and its law 
enforcement partners continue to prioritize the investigation and prosecution of 
defendants that committed these offenses, and the work of recovering 
fraudulently disbursed funds is ongoing. Federal entities and Congress have 
recovered funds through forfeitures and restitution orders and expanded the 
government’s ability to identify and prosecute pandemic-relief program fraud.  
Restitution and recovery. Numerous interagency task forces, such as the 
COVID-19 Fraud Enforcement Task Force led by DOJ, and the Pandemic 
Response Accountability Committee (PRAC) were established to combat 
pandemic-relief program fraud.10 As part of this effort, they have taken steps to 
recover funding that was disbursed as a result of fraud.  
According to the COVID-19 Fraud Enforcement Task Force 2024 Report, as of 
the end of 2023, civil administrative, and civil and criminal judicial cases, resulted 
in the forfeiture of more than $1 billion in fraudulent proceeds.11 According to 
DOJ officials, civil forfeiture actions have resulted in the largest percentage of 
recoveries of fraudulently obtained pandemic-relief program funds. The report 
also noted that, as of the end of 2023, fraud-related enforcement actions from 
pandemic-relief criminal prosecutions resulted in over $882 million in restitution 
orders to both government and private victims.  
In December 2024, the PRAC reported that the PRAC Fraud Task Force efforts 
have led to criminal charges against 111 subjects and assisted the federal 
government in recovering over $16 million in restitution, seizures, forfeitures, civil 
settlements, and voluntary repayments.12 
Extended statute of limitations. For certain pandemic-relief programs, 
legislation has been passed to extend the statute of limitations for fraud (see fig. 
9). 
What actions are being 
taken to address 
pandemic-relief 
program fraud?  

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Figure 9: Statute of Limitation Extensions  
 
Note: In response to these changes, the Small Business Administration issued an interim rule that lengthened 
to 10 years the required records retention policy for lenders that made loans under the Paycheck Protection 
Program.  
According to DOJ officials, there are clear benefits to extending the statute of 
limitations, as it allows law enforcement, investigators, and prosecutors more 
time to uncover potential fraud and to develop cases. A DOJ official also noted 
that an extended statute of limitations would be beneficial, for example, in cases 
when a civil investigation or action leads to the discovery of a potentially complex 
crime that is then referred to DOJ’s Criminal Division for further investigation.  
Continued oversight initiatives. There have also been efforts to continue 
certain pandemic-relief oversight initiatives.  
• 
Special Inspector General for Pandemic Recovery (SIGPR). SIGPR 
was created by the CARES Act to oversee spending of government funds 
in response to the pandemic. In January 2025, legislation was introduced 
to extend SIGPR through 2030.13  
• 
Pandemic Analytics Center of Excellence (PACE). In March 2022, we 
recommended that Congress consider establishing a permanent analytics 
center of excellence to aid the oversight community in identifying 
improper payments and fraud.14 
The PRAC created the PACE, which helps agencies identify potential 
fraud for investigation by combining oversight data in one place with a 
suite of analytic tools. 
PACE is focused on pandemic-relief programs, and its funding is currently 
set to expire in 2025. Ongoing challenges with fraud and improper 
payments highlight the value of these analytical capabilities across the 
federal government.  
While Congress has not acted to authorize a permanent data analytics 
center, the Government Spending Oversight Act of 2024, introduced in 
the 118th Congress, would have established a Government Spending 
Oversight Committee.15 The committee’s general functions would include 
the sharing of data and services, data analytics, and providing analytical 
products to agencies, in coordination with Inspectors General, to promote 
program integrity and prevent improper payments. As of February 2025, 
Congress has not yet passed any bills including these provisions.  
See figure 10 for more information on the oversight initiatives led by SIGPR and 
PACE.  

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GAO-25-107746 COVID-19 Relief 
Figure 10: Oversight Initiatives Led by the Special Inspector General for Pandemic Recovery 
and the Pandemic Analysis Center of Excellence  
 
Pilot programs. DOJ has recently introduced several whistleblower pilot 
programs. While these programs were not designed specifically to address 
pandemic-relief program fraud, they could aid in the identification of these fraud 
cases, if whistleblowers come forward.  
Specifically, the DOJ Criminal Division has launched a Corporate Whistleblower 
Awards Pilot Program for those who did not meaningfully participate in criminal 
activity that falls within specific subject areas, including violations by financial 
institutions, their insiders, or agents. According to a DOJ official, for individuals 
seeking to report previously undetected corporate misconduct who face criminal 
liability for their actions, several DOJ offices are piloting programs that offer a 
different, nonmonetary incentive—the possibility of a nonprosecution agreement, 
subject to certain conditions.  
Additionally, 14 United States Attorney’s Offices created pilot programs designed 
to encourage early voluntary self-disclosure of criminal conduct by participants in 
certain nonviolent offenses. Thirteen of the programs include disclosure of 
criminal conduct involving fraud relating to federal, state, or local funds, which 
would include pandemic-relief program fraud. 
In addition to the actions being taken by the federal government, private citizens 
are helping identify potential cases and reporting them through the qui tam suits. 
For instance, one serial relator—an individual who has filed multiple pandemic-
relief program fraud qui tam suits—brought a qui tam action alleging that 
companies received and retained duplicate PPP loans despite requirements to 
certify that they would not receive more than one loan. The U.S. government 
entered into the lawsuit and, in February 2023, three companies named in the 
suit paid a total of $530,000 to settle the allegations. 
Another serial relator has successfully brought actions alleging violations of the 
loan requirements associated with the second round of PPP funding. Based on a 
review of applicants for a second PPP loan, the relator filed qui tam suits against 
public relations agencies that sought and received forgiveness for these loans. 
Two of these qui tam actions resulted in settlements over $2 million.  

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The fraud triangle outlines three components that contribute to an increased risk 
of fraud seen during the pandemic.16 These components consist of (1) 
opportunity, (2) rationalization, and (3) incentive or pressure (see fig. 11).  
Figure 11: Fraud Triangle 
 
We have previously reported that while fraud risk may be greatest when all three 
risk factors are present, one or more of these factors may indicate a fraud risk.17  
Opportunity. Opportunity refers to circumstances that allow fraud to occur. The 
design of some pandemic-relief programs provided the opportunity for fraudsters 
to take advantage of the limited internal controls in place. For example, federal 
and state agencies relied on self-attestation or self-certification for individuals to 
verify their eligibility or identity to receive assistance from some pandemic-relief 
programs to disburse funds quickly to those in need. While this process allowed 
agencies to get the funds out quickly, it also increased the risk of fraud.  
In addition, cyberfraud increased significantly during the pandemic, in part due to 
the shift to a digital environment—such as an enhanced use of online 
applications. This, in addition to reduced controls for identity and eligibility 
determinations, led to an increase in identity theft that enabled individuals to 
fraudulently apply to certain pandemic-relief programs. 
Rationalization. Rationalization refers to an individual’s justification for 
committing fraud. For example, individuals may find ways to excuse their 
behavior, even when they know it is wrong. In addition, some individuals 
recruited others to fraudulently apply for certain pandemic-relief programs to 
profit. Further, emergency situations may cause individuals to experience 
increased stress, which can lead to a belief where individuals feel they may have 
nothing to lose, resulting in the rationalization of committing fraud.  
Incentive or pressure. Incentive or pressure refers to the stress or urgency that 
leads someone to take an action they may not usually take. According to the 
Association of Certified Fraud Examiners, the line that separates acceptable from 
unacceptable behavior can become blurred for some people, when pressures 
mount.18 
Financial difficulty is a type of pressure that can motivate people to commit fraud. 
For example, by the third week of April 2020, 26.5 million workers had filed 
jobless claims as a result of the pandemic. While financial aid was provided 
during the pandemic, individuals were worried about how to make ends meet. 
What can the fraud 
triangle tell us about 
the culture of fraud 
during the pandemic? 

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GAO-25-107746 COVID-19 Relief 
This concern, and related uncertainty, may have led to individuals feeling 
pressured to defraud pandemic-relief programs.  
Further, as public awareness of certain programs spread, there was an increased 
perception that those programs were easy targets for “get rich quick” schemes. 
This perception may have incentivized certain individuals to fraudulently apply for 
programs they were not eligible for. 
 
Although some individuals might never be swayed from attempting to defraud 
government programs, agencies can implement deterrence actions to help 
prevent future fraudsters.  
Emphasizing consequences. Emphasizing the consequences of committing 
fraud may help to deter future opportunists, as it can shed a light on the severity 
of potential consequences. For instance, a DOJ official noted that the outcomes 
of the pandemic-relief program fraud cases were set forth in press releases to 
promote deterrence, inform the public, and highlight the work of DOJ and its law 
enforcement partners to combat and prosecute fraud. 
Highlighting controls. In the absence of visible controls, some fraudsters, 
including opportunists, may feel more inclined to attempt to defraud a program. 
However, agencies and programs generally have fraud prevention and detection 
controls in place that may not be visible to the public. Therefore, increasing 
awareness of these controls designed to catch misrepresentation could help 
deter fraudsters from committing future fraud.  
Other deterrence mechanisms. As discussed in the Fraud Risk Framework, the 
likelihood that individuals who engage in fraud will be identified and punished 
serves to deter others from engaging in fraudulent behavior.19 For example, as a 
fraud deterrence mechanism, SBA maintains a list of the Small Business 
Innovation Research (SBIR) and Small Business Technology Transfer programs’ 
fraud convictions and findings of civil liability on the SBIR.gov website. 
Highlighting the outcomes of pandemic-relief program fraud cases in a similar 
way may also serve as a method of fraud deterrence. 
 
By examining fraudsters and fraud schemes that emerged during the pandemic, 
agencies can identify fraud mitigation controls that can be implemented in 
emergency environments and during normal operations.  
As discussed in our Antifraud Resource, every fraud scheme has at least one 
fraudster, who may be aided by one or more facilitators.20 Some facilitators 
knowingly participate in fraud schemes by being complicit or coerced. Other 
facilitators may unknowingly participate in fraud schemes. These fraudsters may 
employ various types of mechanisms to defraud federal programs.  
Through our analysis of publicly announced DOJ cases involving pandemic-relief 
program fraud as of December 31, 2024, we found that multiple and various 
mechanisms were used in the pandemic-relief program fraud schemes. For 
example, conspiracy and misrepresentation were mechanisms we identified 
throughout numerous schemes (see fig. 12).  
How can agencies use 
information about the 
consequences of fraud 
to help prevent it?  
How can agencies 
better prepare to fight 
fraud in the next 
emergency? 

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GAO-25-107746 COVID-19 Relief 
Figure 12: Two Types of Mechanisms Identified in Pandemic-Relief Program Fraud Schemes 
 
Mechanisms used in a fraud scheme have a close relationship to internal 
controls. For example, mechanisms of misrepresentation—such as document 
manipulation, false declarations, and fictitious entities—leave agencies open to 
significant fraud risk when they rely on self-certification as an internal control for 
fraud prevention. This was the case in several pandemic-relief programs.21 
Confirming the eligibility and identity of individuals receiving payments, such as 
by confirming wage information or verifying identity through data and other 
checks, are key controls to prevent fraud schemes that rely on such 
mechanisms. 
 
We have released various reports and insights that may help agencies as they 
prepare and plan to implement controls and mitigate fraud risks for future 
emergencies. Considering what was likely lost to fraud during the pandemic and 
assessing what lessons and insights can be taken to better prepare for both 
normal operations and future emergencies is critical for agencies. Beyond 
financial impacts, fraud erodes public trust in government and hinders agencies’ 
efforts to execute their missions and program objectives effectively and 
efficiently. Therefore, taking steps to prevent fraud from occurring is critical. 
Strategic fraud risk management positions agencies to better manage fraud 
during normal operations and future emergencies.  
We previously reported on six key insights identified from pandemic relief that 
can inform fraud prevention.22 
(1) Consider that self-certification alone is not sufficient as a fraud control 
to mitigate misrepresentation. 
(2) Assess fraud risks to include emerging and complex schemes—such 
as those involving conspiracies—from cases affecting other similar 
programs. 
(3) Leverage the Department of the Treasury’s free payment integrity 
services, as well as available program or agency data. 
(4) Address interoperability issues to support future use of data analytics 
for fraud prevention and detection. 
(5) Assume identity information has been compromised, and develop and 
apply upfront controls to verify applicant identity.  
What insights and 
resources has GAO 
provided to help 
agencies develop 
effective antifraud 
strategies? 

Page 17 
GAO-25-107746 COVID-19 Relief 
(6) Ensure payment integrity checks and fraud controls are part of 
program design, with an emphasis on assuring data access and use 
of fraud prevention.  
In addition, our Fraud Risk Framework identifies leading practices for agencies to 
better plan for, and take a more strategic approach toward, managing fraud risks 
in normal operations but also when implementing the federal response to 
emergency situations.23 We have also recommended numerous actions that 
federal agencies should take to help ensure they are effectively managing fraud 
risks and preventing as much fraud as possible up front. For example, we 
recommended that agencies use data analytics to better manage fraud risk. 
These included recommendations to design and implement data-analytics 
activities to prevent and detect fraud, such as using data matching to verify self-
reported information.  
Further, we published a framework for managing improper payments in 
emergency assistance programs.24 While all payments resulting from fraudulent 
activity are considered improper, not all improper payments are the result of 
fraud. This framework discusses five principles that can help federal program 
managers mitigate improper payments, including those related to fraud, in 
emergency assistance programs.  
Finally, in our 2024 report on COVID-19 lessons for federal agencies, we 
highlighted the importance of agencies implementing prepayment controls to 
avoid operating in the “pay and chase model.”25 However, we also noted that 
establishing postpayment controls and processes can help agencies identify and 
recover improper payments and fraudulent payments when the quick 
disbursement of funds makes prepayment controls difficult to apply fully. 
Agencies should act promptly to recover payments because as the more time 
passes, the less likely payments will be recovered. 
Agencies can also apply lessons learned during emergencies to inform future 
practices. During the pandemic, we made recommendations to help agencies 
manage fraud risks, including those in DOL’s UI program and SBA’s PPP and 
COVID-19 EIDL program. For example, in October 2021, we recommended that 
DOL examine the suitability of existing fraud controls in the UI program and 
prioritize residual fraud risks.26 DOL implemented this recommendation in August 
2023. Further, in March 2021, we recommended that SBA conduct a formal 
assessment and develop a strategy to manage fraud risks for the PPP and the 
COVID-19 EIDL program.27 SBA implemented these recommendations in August 
2023.  
 
We provided a draft of this report to DOJ for review and comment. We 
incorporated technical comments from DOJ as appropriate.  
 
To determine the status of cases announced by DOJ that have fraud-related 
charges and civil actions involving pandemic-relief programs, we reviewed public 
statements from DOJ from March 2020 through December 31, 2024. Specifically, 
we identified cases involving various federal pandemic-relief programs (e.g., 
PPP, COVID-19 EIDL program, UI, Emergency Rental Assistance Program, 
Provider Relief Fund).   
We identified these cases using the press releases posted on the Offices of the 
United States Attorney’s website. We also analyzed corresponding court 
documentation available in Public Access to Court Electronic Records to 
determine the current case status and obtain additional details. 
Agency Comments 
How GAO Did This  

Page 18 
GAO-25-107746 COVID-19 Relief 
We analyzed these cases to identify the types of defendants involved, as well as 
the corresponding consequences. Through our analysis, we identified examples 
of DOJ cases that involved various pandemic-relief programs and illustrated the 
different types of defendants that perpetrated the fraud. In addition, we analyzed 
the range of consequences the pandemic-relief program fraudsters faced.  
To identify the efforts taken to address pandemic-relief program fraud, we 
reviewed public information related to DOJ and various program-administering 
agencies’ initiatives, such as the whistleblower (qui tam) initiatives and fraud 
cases originating under the FCA. We also met with DOJ officials to discuss 
general pandemic fraud risk management and prevention practices. 
To identify how agencies can enhance fraud prevention and better prepare for 
the next emergency, we reviewed prior GAO reports to identify lessons learned 
on fraud prevention. We also reviewed reports from relevant oversight agencies, 
such as the PRAC, to identify various approaches to prevent and deter fraud.  
We performed this work under the CARES Act, which includes a provision for 
GAO to report on our ongoing monitoring and oversight efforts related to the 
COVID-19 pandemic. 
We conducted this performance audit from August 2024 to April 2025 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe that the evidence 
obtained provides a reasonable basis for our findings and conclusions based on 
our audit objectives. 
 
The Honorable Susan Collins 
Chair  
The Honorable Patty Murray 
Vice Chair 
Committee on Appropriations  
United States Senate  
 
The Honorable Mike Crapo 
Chairman 
The Honorable Ron Wyden 
Ranking Member 
Committee on Finance  
United States Senate 
 
The Honorable Bill Cassidy, M.D. 
Chair 
The Honorable Bernard Sanders 
Ranking Member 
Committee on Health, Education, Labor, and Pensions 
United States Senate 
 
The Honorable Rand Paul, M.D. 
Chairman 
The Honorable Gary C. Peters 
Ranking Member 
Committee on Homeland Security and Governmental Affairs  
United States Senate 
 
The Honorable Tom Cole 
List of Addressees 

Page 19 
GAO-25-107746 COVID-19 Relief 
Chairman 
The Honorable Rosa L. DeLauro 
Ranking Member 
Committee on Appropriations 
House of Representatives  
 
The Honorable Brett Guthrie 
Chairman 
The Honorable Frank Pallone, Jr 
Ranking Member 
Committee on Energy and Commerce 
House of Representatives  
 
The Honorable Mark E. Green, M.D. 
Chairman 
The Honorable Bennie G. Thompson 
Ranking Member 
Committee on Homeland Security 
House of Representatives   
 
The Honorable James Comer 
Chairman 
The Honorable Gerald E. Connolly 
Ranking Member 
Committee on Oversight and Government Reform 
House of Representatives  
 
The Honorable Jason Smith 
Chairman 
The Honorable Richard Neal 
Ranking Member 
Committee on Ways and Means 
House of Representatives  
 
We are sending copies of this report to the appropriate congressional 
committees, the Attorney General of the United States, and other interested 
parties. In addition, the report is available at no charge on the GAO website at 
https://www.gao.gov. 
 
For more information, contact: Rebecca Shea, Director, Forensic Audits and 
Investigative Service, Shear@gao.gov. 
 
Public Affairs: Sarah Kaczmarek, Managing Director, Media@gao.gov.  
 
Congressional Relations: A. Nicole Clowers, Managing Director, 
CongRel@gao.gov.  
 
Staff Acknowledgments: Gabrielle Fagan (Assistant Director), Christina 
Skinner (Analyst in Charge), Jasmina Clyburn, Lidiana Cunningham, Colin 
Fallon, Megan Huberty, Maria McMullen, and Sabrina Streagle.  
Connect with GAO on Facebook, X, LinkedIn, Instagram, and YouTube. 
Subscribe to our Email Updates. Listen to our Podcasts. 
  
Visit GAO on the web at https://www.gao.gov.  
GAO Contact 
Information 

Page 20 
GAO-25-107746 COVID-19 Relief 
 
This is a work of the U.S. government but may include copyrighted material. For 
details, see https://www.gao.gov/copyright.  
 
 
1GAO, Unemployment Insurance: Estimated Amount of Fraud During Pandemic Likely Between 
$100 Billion and $135 Billion, GAO-23-106696 (Washington, D.C.: Sept. 12, 2023).    
2This includes PPP loans, COVID-19 EIDL program loans, EIDL Targeted Advances, and EIDL 
Supplemental Targeted Advances. Small Business Administration, Office of Inspector General, 
COVID-19 Pandemic EIDL and PPP Loan Fraud Landscape, White Paper Report 23-09 (June 27, 
2023).    
3The statute of limitations for mail fraud and wire fraud prosecutions is 5 years (18 U.S.C.§ 3282), 
except for mail and wire fraud schemes that affect a financial institution, in which case the statute is 
10 years (18 U.S.C. § 3293). The statute of limitations for fraud related to PPP loans (15 U.S.C. § 
636(a)(36)(W)) and PPP second draw loans (15 U.S.C.§ 637(a)(37)(P)) and for certain COVID-19 
EIDL loans (15 U.S.C. § 636(b)(16)), COVID-19 EIDL advances (15 U.S.C. § 9009b(i)), and 
targeted COVID-19 EIDL advances (15 U.S.C. § 9009b (i)) has been extended to 10 years.  
4In January 2025, the Recover Fraudulent COVID Funds Act was introduced that would extend the 
statute of limitations for violations relating to all pandemic-relief programs to 10 years (S. 121, 119th 
Congress). In February 2025, the Pandemic Unemployment Fraud Enforcement Act was 
introduced, which would extend the statute of limitations for violations related to pandemic UI 
programs to 10 years (H.R. 1156, 119th Congress). In March 2025, the SBA Fraud Enforcement 
Extension Act was introduced that would extend the statute of limitations for fraud under certain 
pandemic programs—grants for shuttered venue operators and restaurant revitalization—to 10 
years (S. 1199, 119th Congress). As of April 2, 2025, Congress has not yet passed bills including 
these provisions. 
5GAO, High-Risk Series: Heightened Attention Could Save Billions More and Improve Government 
Efficiency and Effectiveness, GAO-25-107743 (Washington, D.C.: Feb. 25, 2025).  
6Civil actions under the FCA include actions initiated by private persons with knowledge of fraud 
(known as whistleblowers) who can bring suit on behalf of the government. These actions are 
referred to as “qui tam” suits. 
7A settlement is an agreement between parties that ends a dispute and results in the voluntary 
dismissal of any related litigation. A judgment is a final order entered by a court. The Office of 
Management and Budget defines an overpayment as a payment in excess of the amount due. 
Overpayments can result from unintentional errors or fraud.   
8We are reviewing domestic and transnational organized groups engaging in fraud against public 
programs. We anticipate reporting on this ongoing work later in 2025.   
9Association of Certified Fraud Examiners, “Turning the Table on Opportunistic Fraud” (Feb. 6, 
2024), https://centralohiocfe.com/product/turning-the-table-on-opportunistic-fraud-feb-6-2024/.  
10The PRAC was established by the CARES Act in 2020 to oversee pandemic-relief spending and 
coordinate oversight among its member Inspectors General.  
11Department of Justice, COVID-19 Fraud Enforcement Task Force 2024 Report (Washington, 
D.C.: Apr. 2024).  
12Pandemic Response Accountability Committee, Semiannual Report to Congress, April 1, 2024 - 
September 30, 2024 (Washington, D.C.: Dec. 20, 2024).  
13The Complete COVID Collections Act (S. 68, 119th Congress).  
14GAO, Emergency Relief Funds: Significant Improvements Are Needed to Ensure Transparency 
and Accountability for COVID-19 and Beyond, GAO-22-105715 (Washington, D.C.: Mar. 17, 2022).  
15The Government Spending Oversight Act of 2024 (S. 4036, 118th Congress).  
16Donald R. Cressey, a well-known criminologist, developed the Fraud Triangle to help understand 
why individuals commit fraud. 
17GAO, Standards for Internal Control in the Federal Government, GAO-14-704G (Washington, 
D.C.: Sept. 10, 2014). 
18Anthony Campanelli, Kevin Corbett, and Christopher Georgiou, “Fraud Schemes and 
Investigations Amid the COVID-19 Pandemic,” Fraud Magazine (July 1, 2020).  
19GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP 
(Washington, D.C.: July 28, 2015). The Fraud Risk Framework includes a comprehensive set of 
Endnotes 

Page 21 
GAO-25-107746 COVID-19 Relief 
 
leading practices that serve as a guide for program managers to use when developing or 
enhancing efforts to combat fraud in a strategic, risk-based manner.  
20Antifraud Resource. This is an interactive resource meant to inform federal officials, Congress, 
the media, and the public about fraud schemes and how to combat them.   
21We previously reported that federal and state agencies relied on self-attestation or self-
certification for individuals to verify their eligibility or identity to receive assistance from some 
COVID-19 relief programs in order to disburse funds quickly to those in need. For example, one of 
the temporary UI programs—the Pandemic Unemployment Assistance program—initially allowed 
applicants to self-certify their eligibility and did not require them to provide any documentation of 
self-employment or prior income. In addition, the CARES Act initially restricted SBA from obtaining 
federal tax return transcripts as part of the COVID-19 EIDL application process. As a result, SBA 
relied on self-certification when processing loan and advance applications. The Consolidated 
Appropriations Act, 2021, enacted in December 2020, addressed both of these situations. GAO, 
COVID-19: Key Elements of Fraud Schemes and Actions to Better Prevent Fraud, GAO-24-107122 
(Washington, D.C.: Oct. 19, 2023).  
22GAO, COVID-19: Insights and Actions for Fraud Prevention, GAO-24-107157 (Washington, D.C.: 
Nov. 14, 2023).   
23GAO-15-593SP. 
24GAO, A Framework for Managing Improper Payments in Emergency Assistance Programs, GAO-
23-105876 (Washington, D.C.: July 13, 2023).  
25GAO, COVID-19: Lessons Can Help Agencies Better Prepare for Future Emergencies, GAO-24-
107175 (Washington, D.C.: Aug. 1, 2024). 
26GAO, COVID-19: Additional Actions Needed to Improve Accountability and Program 
Effectiveness of Federal Response, GAO-22-105051 (Washington, D.C.: Oct. 27, 2021). 
27GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second Year, 
GAO-21-387 (Washington, D.C.: Mar. 31, 2021).

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