Contractor’s Role as Prime and Sub Under Same Program Upheld
Client Alert | less than 1 min read | 06.30.15
In Enterprise Info. Servs., Inc. v. DHS (June 16, 2015), the Civilian Board of Contract Appeals ruled that a contractor could perform as both a prime and a subcontractor in different functional categories on the agency's EAGLE II program. The Board rejected DHS's argument that a "news alert" prohibiting that practice acted as a modification and had a legal effect on the prime contract in its current state, but the decision did not foreclose DHS from formally modifying the contract to prohibit the practice.
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Client Alert | 3 min read | 04.23.24
DOJ Promises NPAs to Certain Individuals Through New Voluntary Self-Disclosure Pilot Program
On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department.
Client Alert | 3 min read | 04.23.24
Client Alert | 5 min read | 04.23.24
Client Alert | 6 min read | 04.23.24
