The Paycheck Protection Program (PPP) was a tremendously successful COVID relief program. It distributed nearly a trillion dollars in loans to businesses to keep employees on the payroll and stabilize the U.S. economy during the tumult of early 2020. The PPP helped the U.S. usher in one of the strongest economic recoveries in the world.

The PPP needed to hand out money quickly. The pandemic and its effects were a dynamic situation, in which quick and decisive action was necessary.

But that made the program a magnet for fraud. The FBI estimates that tens of billions of PPP dollars were distributed to fraudsters. As the government saw it, though, law enforcement would prosecute fraudsters and recover taxpayer dollars later.

Now, those chickens are coming home to roost. Last week, the Department of Justice announced a blockbuster $120 million settlement of False Claims Act cases initiated by two whistleblowers. The cases involved a PPP lender called Kabbage. That’s unique because most prior fraud recoveries were against PPP borrowers. And with the average PPP loan totaling only $206,000, recoveries have been modest, ranging from tens of thousands of dollars to a few million dollars. The settlement against Kabbage is a precedent-setting milestone that may be a preview of what’s to come.

The settlement involved allegations related to the lender’s certifications of borrower eligibility, which, among other things, required Kabbage to verify the accuracy of payroll amounts that prospective borrowers sought to fund. Kabbage resolved allegations that it inflated those numbers and caused the government to distribute significantly more money than what was warranted under the program’s rules. According to the government’s allegations, Kabbage knew of these errors almost immediately, as early as April 2020, but continued to disperse incorrectly inflated loan amounts.

One of the cases also alleged that Kabbage, in an attempt to process more loans and collect the largest amount of processing fees possible, ignored various controls the program imposed to detect and prevent fraudulent loans, resulting in the issuance of thousands of fraudulent or likely fraudulent loans.

With nearly a trillion dollars at stake, we’re sure to see more large fraud recoveries related to PPP down the line. Whistleblowers are key to launching enforcement actions and recovering taxpayer dollars, as they were in this settlement.