Fraud red-flag checklists

Checklist 02

0 of 8 checked

PPP / SBA loans

Pandemic and small-business loans obtained or forgiven using false information.

Possible programs: False Claims Act, fraud.gov, SBA-OIG

Payroll or employee counts inflated on a loan application
Businesses that did not exist, or had no operations, when the loan was applied for
Fake or altered tax forms, bank statements or payroll records
The same business or owner receiving multiple loans for the same payroll
Loan money used for personal luxury purchases instead of eligible costs
Forgiveness claimed for costs that were not incurred
Straw owners or misstated ownership to qualify as a small business
Loan agents or lenders taking fees they were not entitled to

Checklist 03

0 of 9 checked

Contractors overbilling, delivering less than promised, or cheating on eligibility.

Possible programs: False Claims Act, fraud.gov, agency IGs

Billing for labor hours not worked or by people who do not meet the contract's qualifications
Substituting cheaper or non-compliant parts and certifying they meet specifications
Falsified testing, inspection or quality records
Charging the government for personal or unrelated costs
Inflated prices or hidden markups that violate pricing rules
Falsely claiming small-business, veteran-owned or disadvantaged status (set-aside fraud)
Cybersecurity requirements certified as met when they are not
Bid rigging or collusion with competitors, or bribes to procurement officials
Pressure to bill to the wrong contract or charge code

Checklist 04

0 of 8 checked

Federal grant money misused, misreported or obtained under false pretenses.

Possible programs: False Claims Act, fraud.gov, agency IGs

Checklist 05

0 of 8 checked

Avoiding import duties through false descriptions, values or origins.

Possible programs: False Claims Act (customs fraud), fraud.gov, CBP

Goods declared at a lower value than what was actually paid (undervaluation)
Goods misclassified under a lower-duty tariff code
Wrong country of origin, or transshipping through another country to dodge duties
Two sets of invoices: one for customs and one for the real price
Shipments broken up or relabeled to avoid antidumping or countervailing duties
Products described falsely, such as steel or aluminum declared as something else
Use of shell importers or the identity of an unaware importer of record
Instructions to leave out fees, assists or royalties from the declared value

Checklist 06

0 of 9 checked

Misleading investors or manipulating markets, usually at public or investment-raising companies.

Possible programs: SEC, CFTC (for commodities/derivatives)

Revenue booked early, fake sales or side agreements that undo sales
Financial results adjusted at quarter-end to hit targets
Executives trading on information the public does not have (insider trading)
Investor funds used for something other than what was promised
Guaranteed or unusually steady returns, or returns paid from new investors' money (Ponzi)
Auditors or the audit committee misled, or pushed out when they ask questions
Related-party deals or debts left out of filings
Retaliation against employees who raise accounting concerns
Misleading claims about a product, crypto token or offering to raise money

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