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Separate CAS Noncompliances May Get Separate SOL

Client Alert | 1 min read | 01.22.14

In Appeal of Fluor Corp., the ASBCA held that the government's claim relating to an alleged CAS 403 noncompliance "was a continuing claim inherently susceptible to being broken down into a series of independent distinct events," namely, each payment by the government for a CAS-non-compliant billing. Thus, the board held that, under the CDA's statute of limitations, the government "knew or should have known" that it had a claim against the contractor as of the date the compliance audit was completed (for amounts paid before that date), but that claims for the same alleged CAS noncompliance in subsequent years would not accrue until the amounts at issue for those years had been billed and paid, a result that may save some government claims from the CDA's 6-year SOL (previously discussed here, here, here, here, and here).


Insights

Client Alert | 3 min read | 04.26.24

CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance

On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018.  The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:...