Allison O'Neil and Brian Devine, Partners in Locke Lord's Boston office, shared insights with Massachusetts Lawyers Weekly on next steps for entities that accepted funds through the Paycheck Protection Program (PPP) and engage in business deemed illicit by the federal government, including cannabis companies. O'Neil noted that companies within and outside the cannabis industry have the option to pay the money back to avoid potential pitfalls. Failing that, they should meticulously document how PPP funds were used, she said.
Devine noted that it bodes well for businesses — cannabis and otherwise — that near-term enforcement actions are targeting blatant fraud attempts, rather than companies that made difficult judgment calls about eligibility criteria.
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