Six Non-Profits Agree to Pay Over $3 Million to Resolve False Claims Act Allegations Involving Paycheck Protection Program Loans

            WASHINGTON – The United States Attorney for the District of Columbia announced on September 23, 2025, that it has reached civil settlement agreements with six different non-profit organizations to resolve allegations that the organizations violated the False Claims Act when they applied for and received loans under the Paycheck Protection Program (“PPP”). The announcement was made by U.S. Attorney Jeanine Ferris Pirro.

            In March 2020, the Coronavirus Aid, Relief, and Economic Security (“CARES Act”) was created to provide emergency financial support to Americans suffering economic hardship due to the COVID-19 pandemic. The CARES Act authorized billions of dollars in potentially forgivable loans to small businesses and other entities struggling to pay employees and other business expenses during the pandemic, but the Act also contained important limitations on loan eligibility. For example, the CARES Act permitted certain nonprofit organizations to obtain PPP loans, but organizations organized under Section 501(c)(4) of the Internal Revenue Code were never eligible for such loans. Similarly, Congress prohibited from “second draw” PPP loans those entities primarily engaged in political or lobbying activities, including those entities organized for research or for engaging in public policy advocacy or political strategy or publicly referring to themselves as “think tanks.” The non-profit organizations that entered settled agreements with our Office were alleged to have falsely certified their eligibility for the PPP loans. 

            “You don’t steal money from the federal government, especially when that money should be going to more deserving individuals,” said U.S. Attorney Jeanine Ferris Pirro.

            “The favorable settlements are the product of enhanced efforts by the Small Business Administration’s Office of General Counsel, working with the U.S. Attorney’s Office and other Federal law enforcement agencies to investigate and recover monies improperly obtained from the Paycheck Protection Program, as well as penalties,” said SBA General Counsel Wendell Davis.

            Our Office has entered into settlement agreements with the following organizations.

            Armenian National Committee of America Inc. (the “Committee”) is a Section 501(c)(4) non-profit organization that represents the views of Armenian-Americans on various public policy matters. In April 2020, the Committee applied for and received a PPP loan in the amount of $92,340.91, and the Committee later sought and received forgiveness of that loan. The Committee has agreed to pay $184,681.82 to resolve allegations that it violated the False Claims Act by obtaining a PPP loan for which it was not eligible.

            Center for Immigration Studies (the “Center”) is a Section 501(c)(3) non-profit organization that describes itself as a think tank devoted to the research of U.S. immigration policy. In April 2021, the Center applied for a “second draw” PPP loan in the amount of $366,160 and subsequently received forgiveness of that loan. The Center has agreed to pay $401,299.15 to resolve allegations that it violated the False Claims Act by obtaining a PPP loan for which it was not eligible.

            Diplomatic and Consular Officers Retired, Inc. (“DACOR”) is a Section 501(c)(4) non-profit organization of foreign affairs professionals that describes itself as fostering a public understanding of international affairs and diplomacy. In April 2020, DACOR applied for and received a PPP loan in the amount of $203,032, and the organization later sought and received forgiveness of that loan. DACOR has agreed to pay $355,306. to resolve allegations that it violated the False Claims Act by obtaining this loan for which it was not eligible.

            National Organization for Women (“NOW”) is a Section 501(c)(4) non-profit organization that calls itself the largest organization of feminist grassroots activists in the United States. In April 2020, NOW applied for and received a PPP loan in the amount of $90,339, and the organization later sought and received forgiveness of that loan. NOW has agreed to pay $180,678 to resolve allegations that it violated the False Claims Act by obtaining this loan for which it was not eligible.

            National Women’s Political Caucus Inc. (“NWPC”) is a Section 501(c)(4) non-profit organization that represents itself as dedicated to recruiting and supporting women candidates for elected and appointed office. NWPC applied for two PPP loans, one for $9,582 in April 2020, and one for $7,895 around January 2021. NWPC subsequently applied for and received forgiveness of those loans.  NWPC has agreed to pay $34,954 to resolve allegations that it violated the False Claims Act by obtaining loans for which it was not eligible.

            Third Way is a Section 501(c)(4) non-profit organization that calls itself a national think tank and advocacy organization for certain public policies. In April 2020, Third Way applied for and received a PPP loan in the amount of $974,771, and the organization later sought and received forgiveness of that loan.  Third Way has agreed to pay $1,949,542 to resolve allegations that it violated the False Claims Act by obtaining this loan for which it was not eligible.

            The civil settlements resulted from investigations by Assistant United States Attorney Sean M. Tepe and Auditor Timothy C. Hurley. The United States Attorney further wishes to commend Attorney Caitlin J. Kelly of the U.S. Small Business Administration Office of the General Counsel for her assistance in the investigations.  

            Tips and complaint regarding potential fraud affecting COVID-19 government relief programs can be reported by calling the Department of Justice’s National Center for Disaster Fraud (NCDF) Hotline at (866) 720-5721 or by submitting a NCDF Web Complaint form at https://www.justice.gov/disaster-fraud/ncdf-disaster-complaint-form.

            The claims resolved by the civil settlements are allegations only, and there has been no determination of liability.