1. Home
  2. |Insights
  3. |Mandatory Disclosure And Cooperation To Be Proposed For Commercial Item And Overseas Contractors

Mandatory Disclosure And Cooperation To Be Proposed For Commercial Item And Overseas Contractors

Client Alert | 1 min read | 04.16.08

In a hearing before the House Oversight and Government Reform Committee on April 15, 2008, the Administrator for Federal Procurement Policy indicated that he is inclined to issue a new proposed rule that would subject commercial item contracts and contracts performed overseas to mandatory disclosure to the agency inspector general when the contractor "has reasonable grounds to believe that a principal, employee, agency, or subcontractor of the [c]ontractor has committed a violation of Federal criminal law in connection with the award or performance of [a] contract or any subcontract thereunder." Such proposed rule would also modify a November 14, 2007 proposal, discussed in the linked article by C&M's Angela Styles, to mandate "[f]ull cooperation with Government agencies responsible for audit, investigation, or corrective action" for commercial item and overseas contracts.

Insights

Client Alert | 6 min read | 06.09.26

Is Stock-a-palooza Over? Supreme Court allows SEC to Pursue Disgorgement

On June 4, 2026, the U.S. Supreme Court unanimously held that the U.S. Securities and Exchange Commission (SEC) can continue to pursue disgorgement as an equitable remedy in securities fraud cases without showing pecuniary loss by investors. The Court’s ruling in Sripetch v. SEC resolves a split between the U.S. Court of Appeals for the Second Circuit, which concluded that the SEC must demonstrate pecuniary loss, and the U.S. Courts of Appeals for the First and Ninth Circuits, which declined to require such a showing....