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Investigation and Disclosure Best Practices

Client Alert | 1 min read | 06.06.16

In Importance of Disclosures and Cooperation During and After Internal Investigations, Crowell & Moring attorneys review several recent regulatory changes and highlight the growing importance of targeted communication with the government before, during, and after internal investigations. Among other things, the article lists suspension and debarment statistics taken from the System for Award Management for the first half of fiscal year 2016 to demonstrate the importance of, and benefits that may be achieved from, targeted communication to the government by experienced government contracts investigations attorneys.

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...