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(l-r) Terence M. Grugan, David L. Axelod and Emilia McKee Vassallo, of Ballard Spahr. (l-r) Terence M. Grugan, David L. Axelod and Emilia McKee Vassallo, of Ballard Spahr.

In Part I of our series, we analyzed the spending features of the COVID-19 stimulus packages and introduced the Troubled Asset Relief Program (TARP) as the closest historical analogue to them. In Part II, we discussed TARP in greater detail and highlighted the various ways fraudsters exploited it. Part III examined coordination among various federal agencies and the prosecutions that coordination produced as foreshadowing of what we expect will occur with respect to the COVID-19 stimulus programs. In this final installment, we will look at the CARES Act’s oversight provisions and the ways in which government agencies will likely collaborate to investigate and prosecute those who attempt to take advantage of the act’s funding provisions.

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