I’m not a lawyer. There are provisions in the U.S. Code that make false statements to a federal official illegal. There are well understood requirements for those signing and submitting official statements of compliance to certification rules that there are penalties if these are falsely made. When such violations are discovered, the FAA can take enforcement actions and, if deemed necessary, refer the matter for federal prosecution. All this is probably obvious.
It gets complicated when trying to determine and prove intent. Visibility of what really happened gets difficult when the delegation process reaches the “advanced” stage of ODA, where practically all technical details are within the company and FAA oversight is relegated to a clerical level. It should also be no surprise that the application of “executive judgement” further attenuates or, dare I say, distorts/defeats the process.