I saw no criminal intent among OP's leadership. More likely there were misconceptions and misinterpretations in the early rush.  Seems that multitudes of organizations getting into the PPP program had similar difficulties.  The SBA has recognized that situation and they made some decisions.  One example was when SBA passed Q&A 17:

17. Question: I filed or approved a loan application based on the version of the PPP Interim Final Rule published on April 2, 2020. Do I need to take any action based on the updated guidance in these FAQs?  (bold added)

Answer: No. Borrowers and lenders may rely on the laws, rules, and guidance available
at the time of the relevant application.

And just a couple days ago came this news:  businesses borrowing less than $2 million are considered to have made the certification in good faith. They won’t be subject to additional scrutiny.   

Seems an additional recognition of widespread misconceptions.  Again not grounded in the idea of criminal intent. 

Tom